| A few years ago, California put in place a "Leafy Greens Marketing Agreement" (LGMA) that was deeply flawed. Understandably, enormous agribiz operations are scared of future outbreaks due to the loss of business and profit it poses for them as an entire nation of consumers stops buying their products. Small-scale producers still get hit when an outbreak occurs, but much less so. I rode out the 2006 E. coli outbreak eating spinach the entire time from my CSA farm in Wisconsin. My local co-op's salad bar also featured spinach with a sign on it saying "Wisconsin grown." And even my grandmother - who is not a foodie at all - went to her local farmers market for tomatoes last summer during the salmonella scare.
In other words, these marketing agreements are for the big guys, and they don't care if they hurt the little guys. In the meantime, I care about the environment, "my" farmers, and my food. So here's what's going on now...
A National Leafy Greens Marketing Agreement
A group of agricultural associations "representing the leafy greens industry across the U.S." just sent a letter to the USDA, requesting the establishment of a National Leafy Greens Marketing Agreement (NLGMA). According to their press release:
A NLGMA would implement best practices and a corresponding verification program that could reduce the potential for microbial contamination in these crops.
The group making the request includes:
The United Fresh Produce Association
Produce Marketing Association
Georgia Fresh Vegetable Association
Georgia Farm Bureau
Texas Vegetable Association
Arizona Farm Bureau
Leafy Greens Council
California Farm Bureau
California Leafy Greens Marketing Agreement
Grower-Shipper Association of Central California
Western Growers
The one thing that the press release says that makes good sense is that a national policy would bring some clarity to a myriad of state and local policies. They go on to describe California's LGMA as follows:
The leafy greens industry took immediate action following the E. coli outbreak associated with spinach in 2006 developing and implementing the California Leafy Greens Producers Marketing Agreement within six months of the outbreak. Ninety-nine percent of all handlers participate in the program. They are assessed a per carton fee which is paid to the state department of agriculture which employs USDA-certified inspectors/auditors. The program is administered by a nonprofit organization under state government oversight. A similar program is also now in place in Arizona. The two agreements account for about 90 percent of the nation's leafy greens production.
The California LGMA
It should be noted that one of the key figures in putting the California LGMA in place was Rayne Pegg, who is now the Under Secretary of the Agricultural Marketing Service at USDA. As I wrote about when she was nominated for the position, here are some comments from the Cornucopia Institute about the flaws in the CA LGMA:
[In California] farmers have been asked to take extreme measures with little or no scientific justification. While the rules themselves do not directly eliminate biodiversity on farms, they discourage wildlife and vegetation. As a result, some large produce buyers, such as processors, supermarkets and fast food chains, are using those rules as a precedent to come up with their own standards-often extreme measures without scientific backup.
For example, farmers have been told to destroy hedgerows and other non-crop vegetation around farms that provide important habitat for beneficial wildlife, and to erect fences around their fields, which negatively impacts wildlife corridors. Such measures have not been shown to eliminate or reduce the likelihood of E. coli contamination. "We know natural vegetation surrounding farm fields, which is excellent habitat for birds and beneficial insects, reduces dependence on chemical pesticides and decreases possible ground- and surface-water contamination," Vallaeys stated.
Many growing practices that are the cornerstone of organic and sustainable agriculture would also be discouraged or banned. In California, the rules discourage the development of microbial life in the soil, an outcome that has not been shown to reduce the risk of harmful bacterial contamination. In fact, sustainable farming methods, which promote healthy microbial life in soil, have been shown to reduce E. coli 0157, a deadly variant of the microbe, because the organism has to compete with other microbes and is therefore less likely to thrive.
Farmers already report demands by large corporate buyers not to use certain organic fertilizers. "The aim of these rules seems to promote sterile fields that support few forms of life, except for the leafy greens," added Vallaeys.
Another flaw was that the LGMA was put in place for all leafy greens, not just the bagged ones that present so much risk for foodborne illness. Here is another section of the Cornucopia Institute's press release from a few years back about how small family farms could be harmed by an LGMA:
Small and medium-sized family farms selling whole leaf vegetables instead of bagged vegetables-farms that are almost never implicated in food pathogen outbreaks-would bear a disproportionate share of the financial and logistical burden of such regulations. For example, the rules would likely require testing for pathogens at every harvest. Large-scale, industrial mono-crop producers, which might harvest only one to three times per season, would pay proportionally much less than smaller and more diverse farms that continually harvest many types of vegetables throughout the season.
Thoughts From The Experts
When the announcement of the national LGMA came out, I emailed Will Fantle at the Cornucopia Institute. He said:
This is not unexpected. The new administration is perceived as more pro-regulation. Many of ag's biggest players are trying to get out in front of the food safety regulatory train and shape whatever may ultimately emerge by providing their preferred scheme and hoping it will become the discussion framework upon which everything is built around.
We have distinct concerns about what has been put in place in California. Some of that state's best farmers have been economically injured and disadvantaged by the California Leafy Greens Agreement. In particular, smaller farmers (both organic and those serving local markets) who grow a diverse set of crops have been hurt. Any federal testing protocol for potential food contaminants must recognize that some farmers may harvest multiple sets of fresh produce and crops several times a week during the growing season. These farmers are selling at farmers' markets, as CSAs, and to local retail establishments. Contrast this with a larger grower who harvests a particular crop once or only a few times during an entire season and you can see that uniform, point-of-harvest based food contaminants testing fees penalize diverse growers of fresh food.
At Cornucopia we continue stressing that a "one-size fits all" regulatory and fee-based approach cannot be implemented. If so, it will ruin many of our best farmers who are part of the solution, not part of the problem. We must have fairness in any approach.
One other scale-based point. Some very large produce farms have a national marketing footprint, they are selling a particular crop to a national audience across America. Any contamination of their crops may infect a national consumer base. Local and small producers impact a much smaller population. I would suggest that the largest operations perhaps require more scrutiny due to the potential impact of their crop on the nation's stomachs and health.
Secondly, any regulatory scheme must understand and respect biodiversity in the farm landscape. In fact, in organics, biodiversity is a requirement. For example, vegetative buffers along streams are a sound conservation practice - for run-off and soil erosion controls that impact water and land, and wildlife. Some of the extreme impacts of California's Leafy Greens agreement have pushed the removal of this wise practice - on both conventional and organic farms - in a misguided effort focused on bacterial control. We cannot realistically (nor should we attempt to) sterilize our farm environments.
The primary step in any new national regulatory scheme should be assessing what are the risk factors influencing on-farm contamination of food crops. Given such an approach, it is likely that you will find that the inability to properly manage the mountains of manure found on industrial scale livestock facilities, with their thousands of animals living in tight confinement conditions, ranks at or near the top of the list. These manure mountains threaten to spread contaminants by both air and water. We have to come to grips with these animal livestock factories. And there is even some evidence that a grain-based diet for feedlot cows dramatically increases the number of potentially dangerous E. coli bacteria in the cows gut (as opposed to a pasture-based, grazing approach).
That said, animal manure needs to be reincorporated into the soil - it is a fertility ingredient. Any regulatory plan needs to develop protocols for the proper handling and incorporation of animal manure into the soil. Organics has a much more highly regulated approach than conventional ag for the handling of animal manures. Perhaps some lessons can be learned from its practices.
Cornucopia will be watching this food safety issue closely as it unfolds. The vast majority of our membership consists of organic and/or local family farmers. We will work with consumers and other groups to protect their future in our nation's agricultural system. |
