Federal Regulations Would Harm Sustainable Farmers and Biodiversity

We need your help in another battle to stop the slippery slope toward a sterilized and industrialized food system that threatens biodiversity and the very existence of family-scale farms that grow food in a safe, healthy, and environmentally sustainable way.

In response to the E. coli 0157 outbreaks last year in bagged spinach, the USDA is considering a change in the federal regulations that could potentially require growers of all fresh leafy green vegetables to follow specified guidelines in the fields and during post-harvest handling. The federal rules would be similar to the California guidelines that were set by large-scale operations after the outbreaks. The guidelines include growing practices that discourage biodiversity and sustainable/organic farming practices, deplete soil fertility, and create “sterile-fields-methods” that have not been scientifically proven to actually reduce E. coli 0157 bacteria but are certain to reduce biodiversity, harm wildlife, and burden family-scale farms.

Small- and medium-scale farmers would bear the greatest financial and logistical burden of such specified guidelines. For example, if the rules require testing for pathogens at every harvest – as they currently do in California – then large-scale farms that grow one type of crop and harvest only one to three times per season would pay much less than smaller and more diverse farms that continually harvest many types of vegetables. If regulations dictate a single set of growing practices and food safety measures, which are appropriate for large-scale “factory farms” but not for diverse family farms, we risk losing the very farms that grow leafy greens in a healthy and sustainable way. A one-size-fits-all regulation will not work!

The rules threaten biodiversity and environmental sustainability in several ways. Farmers would be encouraged to eliminate wildlife and any vegetation that may provide habitat for wildlife. The rules also discourage the development of microbial life in the soil. These methods have not been shown to reduce the risk of harmful bacterial contamination. In fact, sustainable farming methods that promote microbial life in soil have shown to reduce E. coli 0157 because it has to compete with other microbes and is therefore less likely to thrive. However, the aim of these rules seems to be for sterile fields that support no forms of life, except for the leafy greens.

We must make our voices heard, telling the USDA that we do not support federal rules that would put a great financial and logistical burden on family-scale farmers, discourage environmentally healthy ways of farming, and harm wildlife.

Taking action is easy, but with a December 3 deadline for submitting comments to the USDA, we need your help today. Please tell the USDA that food safety is an important concern, but that mandating measures with no scientific basis that will put small farmers out of business, and harm wildlife, is not the way to go.

Please submit your comments today by downloading the sample letter below or writing your own message and posting it online (see instructions below), or faxing it in. The USDA is specifically asking citizens to comment on its plan to implement these rules, and it’s important that you tell the USDA that you want to ensure access to fresh, leafy greens and that you oppose a Marketing Order or Marketing Agreement that would impose federal standards for all growers of leafy greens. Remember that every comment counts, but individualized messages/letters carry more weight than form letters.


1) To submit online:

    Go to www.regulations.gov. In the middle of the screen, you will see “Search Documents.”
    In Step 1, choose “Documents with an open comments period”
    In Step 2, choose “Department of Agriculture”
    In Step 3, choose “PROPOSED RULES”
    In Step 4, choose “Docket ID” and then type in “AMS-FV-07-0090”
    Hit “Submit.”

    Next, you will see a column titled “Comments, add/due by.”- Click on the tiny tan dialogue icon, and you are now ready to submit your information and your comment.

2) To fax: (202) 720-8938.

** Please make sure that your letter references Docket Number AMS-FV-07-0090.

In addition to the Cornucopia website more information on this matter is available by visiting the California-based Community Alliance for Family Farmers’ website at http://www.caff.org/foodsafety/. We thank CAFF for their diligence on this issue.

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