Testimony given before USDA’s Fruit and Vegetable Industry Advisory Committee
The Cornucopia Institute
Carlea Arnold, Research Associate
Good morning.
My name is Caralea Arnold. I work for farmers. I’m not a lobbyist. I am a staff member with The Cornucopia Institute, based in Cornucopia, Wisconsin. I grew up on a certified organic farm in upstate New York.
My goal here today, on behalf of the Institute, is to convey a simple message:
In the industry’s attempts to deal with the fallout from numerous pathogen-related contamination incidents, we ask that you please be cognizant of any collateral damage new regulations might have, burdening the thousands of family-scale fresh market producers around the country.
While the vast majority of the most dangerous and well-publicized outbreaks have been tied back to industrial-scale operations, in the United States or abroad, there is a vibrant subset of vegetable and fruit growers that by their very nature create less risk: these are the truly local and/or organic producers.
In the case of organic farms, producers are already highly regulated in terms of nutrient management. For the riskiest crops, they are prohibited from spreading raw manure and are required to compost waste. This practice dramatically reduces any pathogenic content of manure that is eventually incorporated back into the soil as a soil-building and fertility tool. These same farmers are also already required to utilize other cultural practices that significantly cut down on the potential for parasitic and bacterial contamination.
Organic growers are required to develop planning models and document through record-keeping their adherence to federal standards. They are inspected during the growing season by independent third-party certifiers that are accredited by the USDA’s National Organic Program.
Whether large or small, the growing practices on organic farms greatly reduce the risk of contamination to the public.
In addition, authentic, truly local growers are normally owner-operated family operations with an intimate relationship to their customer base, whether that is direct marketing or selling through retail outlets. Many of these growers are also certified organic. Due to their scale, any possibility for widespread contamination and consequent and risk to the public is greatly reduced, owing to their constrained geographic footprint and market.
For these reasons The Cornucopia Institute strongly encourages any future discussion of voluntary or mandated protocols to consider the needs of, and potential damage to, these important growers who have developed profitable niche markets.
Requirements such as postharvest testing can be overly onerous to smaller-scale operations. It’s one thing to require testing of a giant field of spinach in California, harvested maybe once or twice a year. It’s another thing altogether to require the same of a fresh market grower, from Virginia, maybe managing 3 to 50 acres, who might be selling through a farmers market, or a CSA (community supported agriculture) farm. Some of these growers harvest numerous crops 20 or more weeks a year. The cost for frequent testing and labor to implement a program of this nature could drive some of these hard working families off the land.
These high-quality growers put a positive face on this industry and undoubtedly help grow the overall consumption of fresh fruits and vegetables around the country.
There are already disturbing stories of smaller growers in California who have had their livelihoods placed at risk because of new, “voluntary” methods that have now become de facto industry mandates.
There is also the example of the forced pasteurization of raw California almonds. This has significantly raised costs for smaller growers and opened the door to cheaper imports that are not subject to the same treatment mandate.
We encourage you to enter into a dialogue with organizations representing the interests of local and organic growers in order to assure that they are not damaged by future rulemaking that addresses problems that they might very well not be a part of.
In the form of a warning: The Cornucopia Institute filed a federal lawsuit last week challenging the legality of the USDA’s almond pasteurization mandate.
The Almond Board of California, and the USDA, had the opportunity to help forge a compromise position, exempting smaller and organic producers from the almond pasteurization mandate. They chose not to collaborate in that effort and the result might be losing the rule that very well could have had legitimate application for the industry’s largest growers.
Similarly, and to be very clear, we will aggressively defend the interests of family farmers if their economic well-being is threatened by rulemaking that places them at a competitive disadvantage based on their scale. An insensitive one-size rule does not fit all.
I am here today to convey this message upfront, to make possible, before this or any other industry panel considers rulemaking that might have unintended consequences, a call to action. We invite discussion of these issues amicably, before the fact, rather than through debates in the marketplace under intense media scrutiny and the possibility for potential future litigation.
In closing, I would like to thank this panel for their generous listening and the opportunity to speak today. I would encourage anyone from the industry – growers, marketers or regulators who have questions regarding the potential impacts to smaller growers from any new proposed regulations – to contact The Cornucopia Institute at your convenience.
Thank you.
