Act now! Contact your senator before November 18.

Our food safety system is broken. Industrialized food production gives rise to serious food safety problems, and our government’s ability to regulate corporate agribusiness must be strengthened — without harming small-scale and organic family farmers.

Bills in Congress propose to give more authority to the Food and Drug Administration to regulate for food safety, inspect food processing facilities, and order mandatory recalls. The House passed its own food safety bill in July. The Senate’s bill is in committee and scheduled for a mark-up (committee vote) this coming Wednesday, November 18.

Allowing the FDA to crack down on corporate food producers that threaten our citizenry’s health is a step in the right direction — as long as legislation contains protections for small-scale, organic and local food systems. Small farms could be forced out of business by increasing costs for record-keeping, testing and other measures they will not be able to comply with. These are our country’s safest farms — part of the solution, not part of the problem!

Now is the time to contact Senate committee members (especially if one is from your state) that will make changes to the bill on November 18. Our message is: Senate Bill 510 must contain protections for small-scale and organic family farms.

Please call as many committee members as you have time for!

Messages for committee members:

1. Regulate farms and food processors based on risk — with organic and local systems as the lowest-risk.

While no farm and processing plant can be completely safe and completely eliminate food safety risks, different production systems carry different levels of risk. Small and medium-sized organic farms are low-risk farms from a food safety point of view, and local food systems are low-risk systems. This fact speaks to a risk-based regulatory approach, particularly given limited federal dollars available for system-wide regulation and the need to prudently target the use of those funds.

Organic farms are already controlling pathogens and improving food safety in various ways that conventional, industrial-scale farms do not. Specifically, food safety regulation for organic and small-scale producers should focus on education and training, not one-size-fits-all food safety standards.

2. Protect organic farmers from conflicting food safety regulations.

Tell your Senator to ensure that the bill directs the FDA to integrate any food safety standards with the existing federal organic standards. No farmer should be forced to choose between organic certification and food safety rules, and the two should be streamlined to avoid unnecessary additional burdens and incompatibilities.

3. Protect wildlife, biodiversity and habitat from misguided food safety regulation.

Likewise, the food safety bill should ensure that FDA food safety standards do not conflict with existing federal conservation, environmental and wildlife standards. Farmers should be encouraged to adopt conservation practices on their farms — in fact, many conservation practices such as vegetated buffer zones and wetland preservation have been shown to reduce the presence of foodborne pathogens on farms.

Take Action Today – Call Senate Committee Members

See the list below for Senators on the Health, Education, Labor and Pensions (HELP) Committee. Please call or fax their office, ask to speak with the aide in charge of food safety issues, and share the concerns of the small-scale and organic farming community with them.

List of Senate HELP Committee Members

Senator                 Phone                     Fax

Democrats
Tom Harkin (IA)              202-224-3254             No fax
Chris Dodd (CT)                202-224-2823      202-224-1083
Barbara Mikulski (MD) 202-224-4654       202-224-8858
Jeff Bingaman (NM)       202-224-5521             No fax
Patty Murray (WA)        202-224-2621       202-224-0238
Jack Reed (RI)                 202-224-4642       202-224-4680
Bernie Sanders (VT)      202-224-5141       202-228-0776
Sherrod Brown (OH)     202-224-2315       202-228-6321
Bob Casey (PA)               202-224-6324       202-228-0604
Kay Hagan (NC)              202-224-6342       202-228-2563
Jeff Merkley (OR)          202-224-3753       202-228-3997
Al Franken (MN)            202-224-5641              No fax
Michael Bennet (CO)     202-224-5852       202-228-5036

Republicans
Mike Enzi (WY)               202-224-3424       202-228-0359
Judd Gregg (NH)            202-224-3324             No fax
Lamar Alexander (TN) 202-224-4944      202-228-3398
Richard Burr (NC)          202-224-3154       202-228-2981
Johnny Isakson (GA)   202-224-3643       202-228-0724
Orrin Hatch (UT)            202-224-5251       202-224-6331
Pat Roberts (KS)             202-224-4774      202-224-3514
Tom Coburn (OK)           202-224-5754      202-224-6008
Lisa Murkowski (AK)     202-224-6665      202-224-5301

The USDA has announced a series of hearing sessions in September and October across the country to allow members of the public—especially fresh vegetable growers and handlers—to comment on a proposed agreement that would authorize the development and implementation of production and handling regulations for a long list of fresh vegetables, primarily leafy greens.

The proposed marketing agreement would allow corporate leafy green handlers to attach a USDA-backed “food safety seal” to lettuce, spinach, cabbage and other vegetables while prohibiting organic and local farmers at farmers markets, CSAs and roadside stands, and those selling directly to retailers, from using the same seal. This corporate-backed marketing ploy may lead many consumers to assume that vegetables from industrial-scale monoculture farms in, primarily, California are safer than the leafy greens at local farmers markets.

As if this weren’t bad enough,the industry proponents that are pushing this initiative have not been able to show that any set of standards would actually prevent food borne illness. Standards in California, which would likely provide the basis for the national program, have not prevented contamination—today (September 18), a signatory to the California Leafy Greens Marketing Agreement recalled 1,715 cartons of spinach due to salmonella contamination.

Such corporate marketing gimmicks could do real harm to the growing local and organic food movement while having a questionable impact on protecting consumers.

The USDA is not accepting written comments at this time—only in-person testimony will be considered. Hearings will be held in seven locations (CA, FL, OH, CO, AZ, NY, NC), specifics on hearing locations and dates are available at www.cornucopia.org. We

encourage growers and handlers of leafy greens to appear in person at a hearing session to deliver your message.

The safety of our food supply is a vitally important issue, which is why the USDA should not allow corporate handlers to mix serious food safety concerns with self-serving marketing interests.

The Cornucopia Institute has prepared a set of talking points for growers and handlers to use when giving testimony. We urge anyone who is able to attend these hearing sessions to deliver a unified message, which must be heard loud and clear: we do not support a marketing agreement as an appropriate vehicle for improving food safety.

Industry proponents claim they represent more than half, by volume, of the leafy green business in this country. And they may succeed in establishing this marketing agreement.

We must share the following concerns with the Leafy Greens Marketing Agreement:

In the event that the powerful industry players succeed in convincing the USDA to adopt their proposal, we also must propose substantive changes to the marketing agreement, including:

The USDA is especially interested in hearing testimony from growers and handlers of leafy greens. Your testimony at one of the hearings will be an invaluable part of the democratic process—we need as many growers and handlers, and their urban allies, to deliver this important message on the record.

CLICK HERE to see Cornucopia’s detailed TALKING POINTS.

CLICK HERE for specifics on hearing locations and dates.

PLEASE RESPOND to cultivate@cornucopia.org if you are planning to attend one of the hearing sessions or have additional questions.

The “Leafy Green Marketing Agreement,” which requires producers to follow a set of rules (metrics) in the name of food safety, has already shown to be injurious for the environment, biodiversity, and organic growers in California. The USDA is now considering a similar “Leafy Green Marketing Agreement” that would extend beyond California and Arizona to cover the entire United States—let’s help make this rule work for growers of all sizes!

The USDA has scheduled a series of hearing sessions, around the country, inviting you to this perfect opportunity to share your concerns and suggestions.

Click here to view the USDA announcement in the Federal Register.

Make your voice heard!—if you are able to attend, we urge you to speak on behalf of the organic and family-scale farming community. (See below for locations and dates.)

Producers’ experiences in California, where these metrics have been in place for several years, reveal what is at stake. While food safety is a legitimate national concern, organic and small-scale farmers bear a disproportionate economic burden of these metrics. Consider this:

The environmental impacts of the Leafy Green metrics have also been alarming. Since wildlife, non-crop vegetation (wild habitat), and water bodies could be viewed as food safety risks, many environmentally positive, conservation and habitat-oriented practices that growers have implemented in California have been forced to be destroyed or abandoned by growers threatened with the rejection of their crops.

If these metrics are adopted nationally, organic farmers across the nation could face difficulties balancing organic requirements, to promote biodiversity, with metrics seeking elimination of wildlife and non-crop vegetation.

Although the USDA has defined this regulation as “voluntary,” it is important to realize that in California, this has not been the case. Large grocery chains and distributors have refused to purchase produce from growers unless they are a signatory to the “leafy greens” program, making this a defacto rule. Don’t let the voluntary nature of this program dissuade you from recognizing the impact this proposal could have on small, local and organic growers.

The USDA organized public hearings to glean citizens’ concerns and suggestions. The USDA invites you to present evidence at the hearing on the possible economic impacts of the proposal on small businesses.

When and Where:

All hearing sessions are scheduled for 8:30 a.m. – 5 p.m.

Stay tuned! The Cornucopia Institute, in partnership with other public interest groups, will shortly issue a more comprehensive action alert including talking points, information to submit written comments, sample letters and detailed instructions and help regarding appearing at the public hearings (including the precise location of each hearing).

We encourage other NGOs that would like to collaborate on this project to contact us. A number of other groups have also invested in developing an excellent knowledgebase and networking together will leverage our work on behalf of family farmers and consumers.

“How traumatic for my child to have to experience a time that should be of comfort and closeness to me, to be so disturbing and painful,” a mother wrote to the FDA. Her 4-month old infant daughter experienced severe gastrointestinal distress and stomach cramping from infant formula supplemented with DHA and ARA oils. This mother learned that DHA/ARA may cause side effects, and her baby’s symptoms disappeared as soon as she switched to a non-DHA/ARA-supplemented formula.

Another mother had a similar experience with her 3-month old infant son. When her son’s diarrhea disappeared as soon as she switched to formula without DHA and ARA, she wrote to the FDA: “Today was the first day in three months that he actually had a firm stool with no sign of diarrhea.” My baby is not an experiment. Mead Johnson should be ashamed of itself for allowing this to happen and the FDA should take responsibility for our health and the health of our children.”

Help us put an end to this unnecessary suffering and write to the FDA Commissioner today.

We need you to speak up for the helpless infants and distressed parents who have suffered long enough. The Cornucopia Institute and the National Alliance for Breastfeeding Advocacy have filed a petition with the FDA, urging them to require a label notice for all infant food products containing the DHA and ARA oils that are causing such painful side effects in some infants. (A sample letter below will help you voice your concerns.)

It is time for the FDA to take responsibility!

Had the distressed parents contacted the formula manufacturers, these mothers would not have been told to switch away from DHA/ARA-supplemented formula. And nowhere on the formula label or websites do the manufacturers warn of the possibility of diarrhea, vomiting and stomach pain.

While many scientists doubt the benefits of manufactured DHA and ARA oils, little doubt exists that at least a subset of the infant population experiences severe side effects, including watery, explosive diarrhea, severe vomiting, and gastrointestinal distress serious complications in this vulnerable population. Manufactured DHA and ARA fatty acids are structurally different from those found naturally in breastmilk. This structural difference may be one of many possible reasons why some infants experience such severe side effects.

Currently, parents have no way of knowing that their infant’s diarrhea, vomiting, or other gastrointestinal pain may be related to the consumption of formula containing these oils. We need your help to pressure the FDA  this is an important issue that needs immediate attention.

Every day that passes without such a clear warning label could mean another day of pain and serious health repercussions for an unlucky infant whose distressed parents or healthcare providers are unaware that a simple switch to a formula without DHA/ARA could relieve symptoms within a day.

Please write to the FDA Commissioner today.

Feel free to use the sample message below or write your own letter or e-mail message based on the information provided in this action alert or in the comprehensive report titled Replacing Mother – Imitating Human Breast Milk in the Laboratory, available at http://cornucopia.org/index.php/replacing-mother-infant-formula-report/.

Send an email message to: commissioner@fda.gov
or mail your letter to the address in this sample letter:

Commissioner Andrew von Eschenbach
Food and Drug Administration
5600 Fishers Lane
Rockville, Maryland 20857

Dear Commissioner von Eschenbach,

The FDA has received numerous reports from parents and caregivers of infants who experienced severe side effects from consuming infant formula with DHA and ARA oils. While it appears that most infants tolerate these oils, which are extracted from fermented algae and soil fungus with the use of a toxic petrochemical, some infants experience watery, explosive diarrhea, vomiting, and other gastrointestinal distress. These can be serious complications for a vulnerable population.

The Cornucopia Institute and the National Alliance for Breastfeeding Advocacy have filed a petition with the FDA on January 24, 2008, urging you to revise the labeling requirements for infant formulas that contain DHA and ARA from algal and fungal sources. They specifically request a notice on the label of infant formula with DHA- and ARA-containing oils to warn parents of the possibility of adverse reactions to these novel ingredients.

Given the pain and suffering that some infants are unnecessarily experiencing from the consumption of these oils, I urge you to take immediate action. Formula manufacturers are not warning parents that these oils may cause adverse reactions, and parents of suffering infants, and their healthcare providers, have no way of knowing that switching to a non-DHA/ARA-supplemented formula could relieve symptoms within a day. A simple warning on the label of infant formulas could go a long way in preventing any future suffering of helpless infants.

Sincerely,

{{{Your Name}}}

CORNUCOPIA, WI: Small-scale farmers, retailers, and consumers are outraged over a new federal regulation that will require all almonds grown in California to be sterilized with various “pasteurization” techniques. The rule, which the USDA quietly developed in response to outbreaks of Salmonella in 2001 and 2004, traced to raw almonds, mandates that all almonds undergo a sterilization process that includes chemical and/or high-temperature treatments.

Although the final rule was just published in the Federal Register, The Cornucopia Institute, a Wisconsin-based farm policy research group, is asking the USDA to reopen the proceeding for public comment. Cornucopia contends that the rule was never effectively announced to the public, and that the reasoning behind both the necessity and safety of the sterilization processes should be questioned before the rule goes into effect this September.

Click here to read a comprehensive fact sheet on the almond issue. And a sample letter for concerned individuals to send to the USDA has also been prepared by The Cornucopia Institute.

“The new rule is unwarranted and could have many harmful impacts,” said Mark Kastel, senior farm policy analyst at Cornucopia. “The costs of the chemical and heat treatments, in addition to the costs of transporting and recording the new procedures, will be especially onerous on small-scale and organic farmers, and could force many out of business.”

The only exemption to these new regulations will be organic “raw” almonds that will not be fumigated, but will undergo the steam-heat treatment, and small-scale growers who can sell truly raw almonds but only direct to the public from farm stands.

Although foodborne illnesses have garnered headlines in recent years, including contamination of California-grown spinach and lettuce, raw produce and nuts are not inherently risky foods. Contamination occurs when livestock manure or fecal matter is inadvertently transferred to food through contaminated water, soil, or transportation and handling equipment. Raw foods can also be infected by poor employee sanitation either on the farm or in processing facilities.

Glenn Anderson, a small-scale organic almond farmer in the central valley of California, worries that  “This could be one more way for the big companies and the government to put us small farmers out of business.”

The equipment to sterilize almonds is very expensive. A propylene oxide chamber costs $500,000 to $1,250,000, and a roasting line can cost as much as $1,500,000 to $2,500,000.

Anderson also questions the scientific logic behind the rule. He and some other growers believe that the sustainable farming methods they use, such as mowing and mulching, rather than controlling weeds by chemical herbicide applications, protect biodiversity and naturally prevent the spread of harmful bacteria more effectively than the artificial process of pasteurization (sterilization) – which attempts to mitigate contamination after the fact.  According to growers practicing sustainable farming methods, the USDA plan ignores the root causes of food contamination – the dangerous and unsustainable farming practices on industrial farms.

Consumers who oppose the new regulation also worry about its impact on the quality and nutrition of pasteurized almonds, since the Almond Board of California (a marketing arm of the USDA) has conducted the only study on the practice. Their research concluded that “there was no significant degradation in the quality” of the almonds. “The validity of these findings is questionable given the vested interests of the research panel,” Kastel stated.

The most common method of sterilizing almonds is by propylene oxide fumigation. Propylene oxide is a genotoxic chemical and is listed as a possible carcinogen by the International Agency on Cancer Research. In lab experiments, the chemical leads to gene mutation, DNA strand breaks, and neoplastic cell transformation. It is listed as a “possible” carcinogen because no long-term studies have been done with humans. Its use for treating food for human consumption is banned in the European Union, Canada, Mexico, and most other countries.

It is The Cornucopia Institute’s contention that even if independent research concludes that treated almonds are in fact safe, labeling them as “raw” is misleading and deceptive to consumers, many of whom wish to purchase truly raw, unprocessed almonds. “Raw foods are increasingly in demand. The new rule is another case of the public being deprived the opportunity to intelligently choose their food supply,” said Jimbo Someck, who owns and operates four of the country’s leading independent natural food stores, in the San Diego area.

The new regulation to sterilize almonds coincides with the recent announcement by the Food and Drug Administration that it intends to relax its labeling requirements for irradiated food. The FDA proposal will also allow irradiation, the controversial ionization process, to be called pasteurization – a reference that is troubling many food safety watchdogs.

“Consumers deserve to know how their food has been processed,” said Food and Water Watch Executive Director Wenonah Hauter. “Mislabeling irradiated food as “pasteurized” or treated food as “raw” is an industry attempt to make consumers buy products that they otherwise might avoid.”

In light of heightened public concern, the Cornucopia Institute has appealed to USDA Secretary Mike Johannes to postpone implementation of the new regulatory requirements and reopen the almond docket to public comment. Only 18 public comments – all from the almond industry – were received on the proposal. Unlike consumers, retailers, or other organizations concerned with food safety, all almond handlers received a personal letter or fax from the USDA alerting them to the sterilization proposal and inviting them to comment.

“The industry and the USDA tried to slip this through quietly, under the radar, without adequate public scrutiny,” Cornucopia’s Kastel lamented. “We are asking the Secretary of a unit of government that Abraham Lincoln referred to as the “People’s Department” to intervene so concerned citizens can have a say. The close collaboration, away from the eyes of the citizens and the media, we are sure, is not something the Secretary will feel good about.”

According to Andrew Kimbrell, the Director of the Center for Food Safety, “The decision to foist fumigants on unsuspecting almond consumers is just another example of an agency out of control.”

Adds Kimbrell, “USDA is being run lock, stock, and barrel by agribusiness and has abandoned its duty to protect the public and the farming community. This USDA decision, along with FDA’s long-standing refusal to label genetically engineered food, and its recent decision to attempt to label irradiated foods as “pasteurized,” is a conscious effort by the Administration to leave consumers in the dark about the dangers lurking in their food.”

FDA regulations currently require that all single-ingredient foods that have been irradiated and are sold by retailers must be labeled as “treated with irradiation” and must display the radura symbol.