Thursday, February 10, 2011

Food Safety From the Sustainable Farmers View

The FDA was created to protect U.S. citizens. However,  many retired FDA officials go to work as special advisors to the pharmaceutical and food industry. In fact the  FDA (Federal Drug Administration), and USDA (United States Department of Agriculture) officials  frequently retire from office to take lucrative jobs at the companies they were regulating. Sometimes they even go back to the FDA or USDA again later in their career.

Many people naively think the FDA is more interested in protecting them than Big Pharma or Big Agriculture. Guess who they really end up protecting when push comes to shove. If you said big business you win a prize. FDA officials have been caught taking money from big business on numerous occasions. Who knows how many are smart enough not to get caught. The fact that there is a revolving door between pharmaceutical companies and the FDA is well known. Many people think the "FDA Food Safety Modernization Act" is going to increase food safety. I hope they are right but if history continues as in the past, I don't have high hopes for the FDA protecting us in the manner they could. Although there are some very well intentioned people working at the FDA, they are not running the show. The new bill changes make it easier for the FDA to implement control on the food market, but I am concerned about how they will be doing that. Time will indeed tell. In the mean time there are organizations who have pointed out very specific steps we need to take to really make our food safe, nutritious and enjoyable. The National Sustainable Agriculture  Coalition is one such organization that is committed to food safety.  

They have put out the following list as being necessary for a safe food system. 

Sixteen Food Safety Tenets for Sustainable and Healthy Food Systems

1. Food safety is noncompetitive and transparent. Everyone who lifts a fork has a right to safe and healthy food, just as they have a right to choose foods based on the qualities most important to them. ‘Food safety’ should not be a competitive marketing food-trait, lest the most vulnerable people end up with access to only the least safe food, or simply fewer choices. Every person has a right to expect the safest possible food, and a right to absolute transparency about its production processes, no matter what they can afford to pay for it. Completely open, public information about what makes a food ‘safe’ is not negotiable.

2. Effective food safety strategies must be global in reach and effectiveness. ‘Think globally, Act locally’ means that we are all connected, and the consequences of any strategy or intervention must be considered in the context of a global network of relationships. Threats to food safety in any given locale can originate globally. Likewise, the livelihoods of farmers all over the world can be threatened as a result of ill-considered action in any particular locale, region, or nation.

3. Assessment and reduction of risk is at the core of assuring food safety, at every level. All participants in agriculture must be effective assessors and managers of risk. This is made possible through training, education and empowerment of all farmers and farm workers to understand the risks that can enter the process at critical points existing in their operations.

4. Total elimination of risk may be an idealized goal, but is unachievable -- food safety requires constant vigilance and continual improvement. Statements about “zero tolerance” make good public relations copy but are a distraction from the real work of minimizing risk. The changing and interactive nature of microbial pathogens, farm chemicals and other residues of industrial production, coupled with changing human immune tolerances, make grandstanding over ‘zero tolerance’ and ‘eliminating risk’ unrealistic and misinformed. Eradication of pathogens is a scientifically impossible goal, the pursuit of which often sacrifices localized, mid-scale processing capacity. Effective minimization of risk is a more appropriate expectation as compared to the false hope promised by zero-tolerance strategies.

5. No raw food product is inherently risky in and of itself. Risk is an equation with many variables, including the method and manner of production, handling, processing, distribution, delivery and preparation. There is no ‘dirty dozen’ with respect to food. Just because a particular preparation of a crop might be risky (e.g. bagged salads), that does not mean that all production of that crop is risky. The life cycle of a food product, how it is treated throughout all of the stages from production to consumption, is the prime driver of the level of risk that product may carry forward to the end consumer.

6. Concentration in and of itself carries tremendous risk. Food processing and preparation is often done in concentrated facilities, sometimes several days, weeks or months prior to a “use-by date.” Food is then shipped all around the nation and the planet. The risks inherently associated with this far-reaching chain of activities have not been adequately explored, contributing to the tendency to pass responsibility back to farms and farmers. The consequences of concentration and global distribution need to be fully explored and integrated into risk assessment and enforceable food safety best practices.

7. Food safety begins at the farm, on every farm. All farms, farmers, and farm staff, from the owners to the most transient farm helpers, have a role in producing safe food. Respect for farmers and concerns of farm workers is a critical foundation of any food system, and is essential to building and maintaining customer confidence in our products.

8. We are all responsible. Along the paths from the farms to individual kitchens, food can change hands, change ownership and form many times. At every turn, risks are introduced that far exceed those resulting from most on-farm activities. Public health requires awareness and effort from each of us, even in our own kitchens. Ultimate vigilance at the farm will not demonstrably reduce risk further along the supply chain. Efforts to unnecessarily push concerns back to the farm often hurt farmers and do little to assure food safety.

9. We cannot test our way to acceptable food safety. Testing along the chain of food production and distribution yields data necessary for the understanding and abatement of systemic risks. Data are needed from many critical points along the food chain to support scientific inquiry, continuous improvement and better practices. However, over-emphasis on testing disproportionately burdens smaller producers and processors while yielding only marginal results. In an equitable food system, testing is not a “cost of doing business,” but a public health requirement, and should be funded and administered in a way that does not unduly increase the negative impact on smaller operations.

10. Effective policies and practices are rooted in science and proven systems of production. An open, ongoing and transparent scientific effort to understand risks and alternative interventions is needed. The reality of an ever-shifting landscape of microbial pathogens, in which new risks emerge regularly, requires open-minded scientific inquiry and sharing of research on best practices. Scientific concepts such as vegetative buffering, the effects of biological diversity, and the potential for diverse, beneficial microbial populations to act against pathogenic microbes, deserve equal consideration alongside traditional, reductionist, “search and destroy” approaches. In pursuing evidence-based solutions, we cannot afford to leave any stone unturned or ignore the stones turned over by any solid scientific effort.

11. Food safety includes chemical and physical hazards, in addition to food-borne pathogens. While the major focus of food safety is often the reduction of health risks associated with microbial, food-borne pathogens, solutions must also address physical hazards posed by chemicals, antibiotics, and other processing and packaging residues. Though such hazards may have slower, longer-term effects than microbes, they often pose more expansive threats and cannot be ignored in a comprehensive food safety strategy.

12. HACCP as used in food processing facilities is not appropriate on farms. Although risk is managed and reduced at critical control points, true HACCP is most valuable when applied to controlled environments such as manufacturing plants. Farms are biological systems and have few uniform ‘control points’ where HACCP can be relevant or effective. However, HACCP can provide a valuable framework for systematic thinking in the development of any on-farm food safety plan, and in risk management training programs.

13. Federal efforts to enforce minimum standards of food safety must be integrated and respectful of state and local government stakeholders. Establishment and enforcement of baseline standards, especially in areas of greatest known risk, is an important responsibility of government. Federal, state and local agencies need to work together in a consistent fashion to tailor enforcement that is appropriate and effective in light of local and regional realities, reinforcing a multi-stakeholder process of continuous improvement.

14. Government intervention alone cannot achieve absolute protection of public health. Unless we are to cede to our government unlimited resources along with abdication of our civil liberties and freedom of choice, government entities cannot guarantee safe food by themselves. Support of a democratic, small-business-friendly food system will require many other effective layers of ongoing activity and cooperation in addition to government intervention. The role of government regulation should be limited to those loci of risk that are most universally understood and far-reaching in impact.

15. Overextended regulation and intervention will harm all players in the food system. Adding disproportionate expenses to farms and food producers that already depend on slim margins will reduce opportunity and create barriers to entry for producers of all scales. Overextended regulations will undermine private and voluntary systems of training and continuous improvement, and will undermine any sense of “shared responsibility” among all food-system players, ultimately harming the public the regulations purport to protect.

16. A healthy societal attitude toward risk is essential to understanding and achieving a safe, secure, and sustainable food supply. It is in the very nature of risk that it can never be eliminated altogether and often increases in unintended places when reduced in others. The many routine risks in daily life far exceed those associated with ingestion of any food or encounter with our modern food system. This does not excuse any actor from responsibility to do the best possible job in bringing safe food to the public. However, it serves as a reminder that the cost-benefit ratio can easily turn against public well-being and must be closely observed. Sustainability is a progressive attitude affecting not only the production, processing, and marketing of food, but also its consumption and enjoyment. Such an attitude would suggest that the reality of “safe, clean food” exists largely in the increasingly educated preferences – and pocketbooks – of the beholders.

(Yes my friends, it is so important to vote with your pocketbook and get your friends and family to do the same thing. If you don't want GMO food, don't buy it. If you want safe food in general, grow it or buy from those whom you know you can trust!) 

The National Sustainable Agriculture Coalition (NSAC) is an alliance of grassroots organizations that advocates for federal policy reform to advance the sustainability of agriculture, food systems, natural resources, and rural communities. To learn more abou them go to: