To the 900,000 supporters of the Center for Science in the Public Interest (CSPI), the organization seems to have the interests of our agricultural producers at heart. After all, they launched Food Day, “a nationwide celebration and a movement for healthy, affordable, and sustainable food.” Across the country, organizations involved in food production, food justice, cooking and health are celebrating. Their Food Day website is full of articles about “eating real” and sustainable food production and a celebration of fresh, local food production.
But CSPI’s recent actions related to the Food Safety Modernization Act are not very local-food- and farming-friendly. They have filed three comments related the Preventive Controls Rule that will impose costly requirements on farms that minimally process their products, or farms that aggregate the products of other farms. The rule includes exemptions and alternative requirements for small and mid-scale producers.
CSPI wants fewer farms to be exempt from the rules. In their comments, they propose that FDA severely restrict the scope of the exemptions. They also ask FDA to impose additional record-keeping and documentation requirements that will make it more difficult for farmers to establish their eligibility for the exemption.
Consumer and producer organizations are on the opposite side of this issue. We want more farm facilities to qualify for the alternative compliance provisions. We want to continue the growth of local and regional food markets and increased access to locally produced products.
Do you think that every exempt farm should have to file tax and other financial documents with the FDA to prove they are exempt? CSPI does.
CSPI wants to add costs and complexity for exempt farm facilities. CSPI demands that farms establish that they are exempt every year — rather than every other year, as the proposed rule requires. CSPI thinks that self-certification as required under the proposed rule isn’t adequate — farm facilities should have to submit actual records or true copies of their financial records.
Most consumers and producer organizations recognize that placing onerous record-keeping requirements on our small producers doesn’t make food safer; it just makes it too costly for these producers to bring local food to market.
To add insult to injury, CSPI clearly doesn’t think our producers are very trustworthy. They want FDA to include a statement on the web page where exempt farm facilities register that says, “It is a crime to make a materially false, fictitious, or fraudulent statement to the U.S. Government.”
Happy Food Day, indeed.
What kind of food are you celebrating on Food Day? Is it the fresh produce at the farmstand, the surprises each week at your CSA, the cornucopia of fresh and delicious food that our family farms bring to your market and table? If so, then please don’t model your food safety comments after CSPI. Instead, join the thousands of consumers and producers throughout New England who are asking that FDA create food safety rules that will make it possible for our smaller scale producers to continue feeding us delicious, local food.
Please submit your own comment. Let’s make sure that every day is Food Day.
Here is a link to a letter that a CSA sent to its members, encouraging them to comment to FDA about the proposed rules. See NEFU’s website for talking points and instructions on how to make a comment.