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Marketing proposal won't work for smaller farmers

CORNUCOPIA, Wis. -- Corporate agribusiness wants to tell the rest of us how to farm, and shut anyone out of the market who does not follow their one-size-fits-all "food safety" standards for leafy green vegetables.

CORNUCOPIA, Wis. -- Corporate agribusiness wants to tell the rest of us how to farm, and shut anyone out of the market who does not follow their one-size-fits-all "food safety" standards for leafy green vegetables.

USDA is supporting the plan, which, if accepted, will allow a committee of industry representatives, lobbyists and other officials to write a set of so-called food safety standards for the entire leafy green farming community. This could competitively injure smaller, local and organic producers.

If passed, leafy green handlers and marketers who sign on to this agreement will require every grower they buy from to follow a uniform set of standards, which will be written with large-scale, monoculture, chemical-intensive farming methods in mind.

Farmers do not sign on to the agreement -- their buyers (brokers, distributors and supermarket chains) do. Sustainable organic and local growers who take different approaches to food safety likely will be shut out of the market when buyers refuse to buy their crops.

With the recent passage of the Food Safety Modernization Act, this proposal by industrial-scale, monoculture interests for industry self-regulation simply is unnecessary and counterproductive.

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This plan is proposed in the name of food safety, but fails to tackle the root of our nation's food safety woes: the unnatural rearing and feeding practices of conventional beef and dairy cows, hogs and chickens on industrial-scale "factory" farms. There is nothing inherently dangerous about leafy greens -- the problem lies in contamination of surface and groundwater, and even the air in farm country, from our nation's filthy feedlots and animal factories.

Proposal problems

What's wrong with the proposal?

n Industry self-regulation is the wrong approach to food safety. The Leafy Greens Marketing Agreement will give industry representatives authority to self-regulate for food safety, doing a disservice to the public's need for safer food.

n The USDA Agricultural Marketing Service has no food safety experience or expertise. With the recent passage of the Food Safety Modernization Act, which gives greater authority to the Food and Drug Administration to regulate for food safety, there is no need for the USDA's Agricultural Marketing Service to get involved in food safety through industry self-regulation.

n Wildlife and biodiversity: Experiences in California have shown that industry-driven food safety measures ignore important environmental, wildlife and biodiversity concerns. The California LGMA has resulted in the wholesale loss of wildlife habitat and destruction of natural vegetation, though it has not been proven that these are material factors in food contamination.

n The NLGMA will be a setback for the organic movement. With the current proposal to reserve only one slot on the 26-member committee for an organic producer, the food safety benefits of organic and sustainable farming practices likely will not be factored in to the LGMA's standards. Organic and sustainable farmers who choose not to follow the standards likely will be shut out of the market, doing irreparable harm to the growth of the organic and sustainable farming movement -- and the availability of organics for consumers.

n The proposal fails to address the root of the problem. The LGMA metrics will do nothing to tackle the root of the problem, which is, in most cases, bacterially tainted manure from confined animal feeding operations that contaminate nearby fields and waterways.

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n One-size-fits-all standards hurt family farmers. It is unclear how a set of national rules can accommodate both large-scale, monoculture growers in one part of the country and small-scale, diversified farms in other regions in the U.S. Rules that may be appropriate for one type of farm may put unnecessary burdens on other producers -- and with large-scale growers setting the standards, chances are that the smaller-scale and diversified farms' needs and concerns will be the first to go. If any problems occur, these events are isolated given smaller geographical marketing footprints. It would be a blow to produce safety if this growing trend toward diffuse, regional production is competitively injured.

The deadline to submit comments on this proposal is July 28.

To submit comments electronically: electronically . By email: Melissa.Schmaedick@ams.usda.gov , with "AMS-FV-09-0029" in the subject line. By mail: Hearing Clerk, United States Department of Agriculture

1400 Independence Ave., SW., Room 1031-S Washington, DC 20250-9200.

Editor's Note: The Cornucopia Institute, based in Cornucopia, Wis., is a nonprofit farm policy research group.

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