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Stop the National Leafy Greens Marketing Agreements before it stops family farms from providing our fresh vegetables!
The USDA Agricultural Marketing Service (AMS) has proposed a National Leafy Greens Marketing Agreement (NLGMA), and has posted it for public comment through July 28. This NLGMA is entirely unnecessary because the new Food Safety Modernization Act has placed food safety oversight where it belongs – the Food and Drug Administration (FDA) – and (thanks to all the work of the National Sustainable Agriculture Coalition’s Food Safety Task Force) this Act includes measures to minimize unnecessary burdens on smaller farms and businesses. The NLGMA is modeled on similar Leafy Greens Marketing Agreements in California and Arizona, which have not only created tremendous barriers for small and midsize farms, but also mandate destruction of wildlife habitat, conservation buffers, and beneficial insect habitat for biological controls.
Now is the time to let the USDA know that we oppose the NLGMA. Submit your comments by July 28. Letters from farmers stating how the proposed agreement would harm their operations and thwart their ability to provide safe, healthful food to consumers seeking fresh, local and/or organic, would be especially effective. Following is a link to a website where you can submit comments.
Go to http://www.ams.usda.gov/LeafyGreensAgreement and click on “Submit a Comment” on the right side.
See below for more information on NLGMA from the National Organic Coalition.
More on NLGMA – from National Organic Coalition
Remember the Food Safety Modernization Act (FSMA) that passed last year? We won a hard fought battle, securing appropriate food safety rules for small-to-midsized farms and processors producing fresh, and healthy food for local and regional markets. This law will be implemented by one of the agencies with food safety authority – the Food and Drug Administration (FDA).
Now, USDA’s Agricultural Marketing Service, an agency with no food safety expertise or authority, is proposing to establish a set of food safety regulations for leafy greens (spinach, lettuce, and cabbage) growers and handlers who sell into the wholesale market, called the National Leafy Greens Marketing Agreement (NLGMA).
The most powerful “Big Ag” players in the leafy green industry are pushing the National Leafy Greens Marketing Agreement (NLGMA). The sellers, processors, or distributors that sign on to the rule will require that the farmers they purchase from comply with its standards. The rule adds a second and conflicting layer of food safety standards and audits on top of FDA food safety rules.
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HOW TO COMMENT:
USDA is seeking written comments from the public on the NLGMA proposal by July 28. Write USDA today to urge them to reject this proposal.
Go to http://www.ams.usda.gov/LeafyGreensAgreement and click on “Submit a Comment” on the right side.
Here are some suggested points to make:
I oppose the creation of a National Leafy Green Marketing Agreement, which I believe to be the wrong approach to address food safety concerns.
The Agricultural Marketing Service is not a food safety agency. It is bad public policy to create food safety regulations in order to address the “marketing” goal of increasing consumer confidence in the safety of leafy greens. Food safety policies should be driven by science, not by marketing problems.
The NLGMA, as proposed, would give the large conventional produce industry the ability to use its own world view to dictate farming practices. Small scale and organic farmers would have a very small voice in the standard-setting process.
The NLGMA is modeled on state food safety agreements in California and Arizona. In those examples, the conventional produce industry has pushed through food safety regulations that are biased against organic and small-scale farmers, have led to the destruction of wildlife habitat and discouraged good conservation practices on farms. See pictures from Wild Farm Alliance at http://www.wildfarmalliance.org/Press%20Room/press_room_destruction.htm
Diversified farming operations with complex rotations have been shown to be beneficial to the environment. Yet crop-by-crop food safety regulations, such as the NLGMA, are an economic disaster for diversified farming operations, and are biased toward large mono-cultural operations. For a farmer with 40 crops on 100 acres to comply with 40 different food safety regulations is prohibitively burdensome. Crop specific food safety regulations, such as NLGMA, will drive farmers out of environmentally sensitive diversified crop production, and toward chemical-intensive mono-cultural operations. This is counter to the goals of food safety and more environmentally sound agriculture.
The Food and Drug Administration is currently writing regulations to establish food safety standards for produce. Why is AMS proposing to establish standards that conflict with or duplicate the FDA standards, with the conventional leafy greens handlers in the drivers’ seat?
The NLGMA is a disaster waiting to happen, for farmers, consumers, the environment, and ultimately for food safety.
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BACKGROUND
Also see the Action Alert and Comment Form from the National Sustainable Agriculture Coalition (NSAC) at http://sustainableagriculture.net/blog/%E2%80%9Cbig-ag%E2%80%9D-at-it-again/
The NLGMA was originally proposed by a group of large conventional produce industry organizations as a way to give those organizations the authority to set food safety standards for leafy greens vegetables, in order to restore consumer confidence in leafy greens, in the aftermath of the 2006 e.coli outbreak in spinach. The proposal would allow the produce industry to establish food safety standards for leafy greens production and handling, with input and approval by USDA. These industry-established standards would become the dominant standards in the industry, and all farmers selling product to the handlers that are signatories to the Agreement would be required to follow the farming methods prescribed by the Agreement.
The proposal is mirrored on state marketing agreements already in place in California and Arizona, in which the conventional produce industry has been able to dictate farming practices that are in conflict with organic standards, are economically harmful to small scale and diversified farming operations, and have lead to destruction of wildlife habitat and other on-farm conservation measures.
In late 2009, USDA held hearings around the country to seek public input on the produce industry’s proposal for a NLGMA. After receiving thousands of pages of testimony in opposition to the industry proposal from organic and small-scale farmers, consumers, conservationists, and natural food retailers, USDA has sided with the industry to move forward with a USDA-backed NLGMA. See some of those comments from NOC and others.
The Agricultural Marketing Service is NOT a food safety agency and it should leave food safety regulation to the Food and Drug Administration. AMS staff is made up of economists and marketing specialists who convene industry to reach agreement on orderly marketing of produce. They are NOT food safety scientists.
Making matters worse, USDA’s Agricultural Marketing Service (AMS) does not have the authority to write food safety standards for produce, because that authority rests with the Food and Drug Administration (FDA). The FDA is currently in the process of writing produce food safety regulations, as required by comprehensive food safety legislation enacted by Congress last year. Despite this fact, AMS is still proposing to let the industry write its own food safety standards for leafy greens, under USDA control. The last thing farmers need is to have to comply with FDA food safety standards and potentially conflicting or overlapping standards from USDA.
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