Our food safety system is broken. Toxic food-borne pathogens like E. coli O157:H7 and salmonella are no longer just contaminating meat and eggs, but have caused outbreaks in traditionally safe foods like spinach, peppers, tomatoes, and nuts.

Yet instead of addressing the root of the problem, lawmakers and regulators in Washington, D.C. have rushed to action, proposing to fix our food safety system with band-aid solutions that may actually threaten the small-scale, organic and local farms that are part of the food safety solution. We cannot let this happen!

A highly centralized, chemical-intensive, corporate-driven agricultural system, deeply out of balance with nature, lies at the root of our nation’s food safety woes. Any proposed bills and rule changes must recognize and address the root causes of food-borne illness outbreaks, as well as acknowledge and protect the unique benefits of organic farming and local food systems.

For example, while manure infected with dangerous bacteria from grain-fed cattle in crowded feedlots has been linked to contaminating our food supply, not a single bill in Congress or regulatory proposal at the USDA or FDA acknowledges this problem—much less tries to solve it. In fact, the food safety bills in Congress entirely exempt animal agriculture from stronger regulation, placing added regulatory burdens solely on the shoulders of the fruit and vegetable growers and processors whose products may have been contaminated by feed-lot manure pathogens.

And in the rush to find a solution to our food safety problems, numerous lawmakers and government officials have put forward their own proposed solutions—creating a confusing array of food safety bills, proposed rule changes, revised guidance documents and even court cases.

To help people cut through the confusion, The Cornucopia Institute developed an organized chart of current legislative and regulatory proposals. For each proposal, we outline different avenues for taking action, sample talking points, due dates and addresses for sending in comments, and websites for additional information. The document will be periodically updated as new developments occur.

We hope this information will help farmers and consumers of organic and locally-grown foods send the message to Washington D.C. that food safety reform should recognize the unique value of organic and local food systems to food safety, and should contain protections for these farms and not needlessly place them at a competitive disadvantage due to their style of operation.

We encourage people to take action by contacting the lawmakers and agencies. Information on how to take action, deadlines and addresses for sending comments, and sample talking points are offered here.

Send Your Comments to USDA on Draft Environmental Impact Statement

Late last year, the USDA released a court-ordered Environmental Impact Statement (EIS) on Monsanto’s new genetically engineered Round-up Ready Alfalfa. A federal lawsuit, led by the Center for Food Safety and joined by The Cornucopia Institute and other plaintiffs, was won in 2007 compelling the USDA to conduct their first-ever environmental impact statement on a genetically engineered (GE) crop, alfalfa.

Perhaps unsurprisingly, the USDA’s assessment approves of releasing a new genetically modified crop into the environment, despite the known risks this version of alfalfa poses to organic livestock agriculture.

Public comments are being accepted until February 16. Please let the USDA hear your voice. A broad coalition, composed of both organic and conventional farmers, is opposing Monsanto’s RR Alfalfa and the USDA particularly needs to hear from those involved with organic agriculture.

Alfalfa is the fourth most widely grown crop in the U.S. and as a farmer, you know it is a fundamental source of livestock forage. Here are some key observations, based on reviewing the 1400 page EIS.

• This would be the first perennial crop to be approved for genetic modification and release. Alfalfa is open-pollinated by bees. With bees traveling 4-6 miles, they can potentially spread the patented, foreign DNA to distant conventional and organic crops. The potential for biological contamination from a neighbor’s field, even miles away, threatens the livelihood of organic farmers, dairies and other livestock producers. U.S. organic standards prohibit genetic engineering. Buffer strips and other devices required with other GE crops are essentially useless.

• As a perennial, it is very likely that genetically engineered volunteers will escape from farm fields and/or be scattered along roadsides from harvest and transport equipment. Escaped or feral plants will live on for years producing GE pollen to contaminate non-GE alfalfa.

• The USDA’s EIS maintains that avoiding GE contamination would be your responsibility as an organic producer. They say that all you have to do is change your planting and harvest schedules to “avoid simultaneous flowering” with RR alfalfa in your neighbor’s field, and “disallow or remove commercial beekeepers’ hives anywhere near your alfalfa field.” Is this feasible? Tell the USDA that they need to protect all farmers and the livelihoods of those who choose not to grow RR alfalfa.

• Ninety percent of all the alfalfa seed sold in the US comes from 5-6 compact geographic areas ideal for growing the seed in the Pacific Northwest and Canada. Yet the USDA’s EIS fails to recommend significant isolation zones where the planting of GE alfalfa would be illegal, and help to protect the vital nature of uncontaminated alfalfa seedstock.

• The vitality of the $25 billion organic industry is at risk. Our partners, the consumer, support organics because they want healthy foods, sustainability and economic opportunity for family farmers. How will they react to contamination of the organic dairy and beef sector by genetically modified crops? Genetic engineering is prohibited in organics and organic consumers, as well as organic farmers, don’t want it.

• The USDA’s EIS concludes that RR alfalfa will cause production to shift to larger farms, but they say this is “not significant.” Let them know that this is significant to you as a family-scale farm operator (you could very well become collateral damage under their forecast).

• The EIS predicts that export markets for alfalfa will be lost, but again does not consider this impact “significant” nor offer any possible means to prevent it. The majority of alfalfa seed exports go to Saudi Arabia and the majority of alfalfa hay exports go to Japan and South Korea, all of which will reject GE-contaminated seed and hay, causing significant harm to the export industry. How does this help American farmers?

• During our discussions with many seed and plant experts, not associated with Monsanto, they all said in a few short years, all alfalfa seed will contain considerable GE contamination. This is what has happened with canola seed, as an example. Should the USDA proceed with introducing alfalfa, as suggested in the EIS, there will soon be no organic seed available from the US. Then the patent holders can, if they wish, push all non-GE seed growers out of business the same way they have hurt soybean seed savers; Monsanto will end up having a monopoly on all alfalfa seed grown in the US. Organic producers will have two choices: switch to other legumes or buy organic seed from foreign sources. Tell the USDA you want your chosen form of agriculture protected, not taken from you by the development of RR alfalfa.

The USDA’s stated basic mission is “protecting American agriculture.” They say they support the “coexistence” of all types of agriculture. Let them know that they must include a future that protects organic and alfalfa farmers and conventional exporters from contamination by RR alfalfa.

SEND YOUR COMMENTS TO THE USDA BY FEBRUARY 16.

Comments can be filed online at: http://www.regulations.gov/search/Regs/home.html#submitComment?R=0900006480a6b7a1

Written and mailed comments (please send two copies) should be sent to:

Docket No. APHIS-2007-0044,
Regulatory Analysis and Development, PPD
APHIS, Station 3A-03.8
4700 River Road Unit 118
Riverdale, MD 20737-1238.

Please state at the top of your written or electronic comments that they refer to Docket No. APHIS-2007-0044.

If you would like more information, you can review the draft EIS here: http://www.aphis.usda.gov/biotechnology/downloads/alfalfa/gealfalfa_deis.pdf

“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.

“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.