The U.S. Food and Drug Administration (FDA) is currently proposing regulations that could have a profound impact on the way wildlife habitat and other conservation practices on farms are managed. Earlier this year the FDA released their proposed (a.k.a. draft) set of rules for the Food Safety Modernization Act (FSMA)---the first major overhaul of our nation's food safety practices since 1938. When they become law, the FSMA rules will require the implementation of certain food-safety management practices on many fruit and vegetable farms. While addressing food safety on produce farms makes sense, if not written correctly, these regulations could encourage the needless destruction of wildlife habitat near produce fields.
The FDA is seeking public comments on the proposed FSMA rules by November 15th of this year. Wild Farm Alliance (WFA) has been reviewing the rules and analyzing how they may impact conservation-based and sustainable farming practices. During our initial review, we found major problems in the proposed rules related to issues concerning wildlife, domestic animals and soil amendments. Once we have finished our analysis, we will share our findings. This is when we will need your help! We need farmers and conservation specialists to let the FDA know how these proposed rules may affect farm operations, as well as local/regional conservation efforts. Everyone plays their part in ensuring safe food from farm to fork, but the FDA needs to hear that the practices aimed to reduce food-safety risks on the farm should avoid impacts to water quality, wildlife and habitat.
So, What Does Food Safety Have to Do With Biodiversity Conservation?
A Lot More Than You Might Think...
Everyone---from farmers, to processors, to consumers---has a role in ensuring safe food from the field to the table, but some current, misguided food-safety practices have encouraged the destruction of wildlife habitat and conservation plantings on farms. In 2006, an outbreak of E. coli O157 from spinach was traced back to a farm on California's Central coast, the home of our nation's fresh-cut salad industry. While it was never determined how the spinach became contaminated, a finger was pointed at wildlife as a source of food-borne pathogen contamination (even though research so far has indicated that native wildlife pose a low risk of carrying human pathogens). Wildlife and the habitat they inhabited became suspect in the eyes of the leafy-greens industry. Buyers purchasing leafy greens from growers often refused to buy lettuce or spinach that came within a certain distance of wildlife habitat. A grower might be asked not to harvest any of the spinach within 30 feet of a grassy drainage ditch, or within 50 feet of a windbreak of trees and shrubs. To avoid losing production area, many growers were subtly pressured into removing conservation plantings from their land. Chainsaws were taken to windbreaks, grassed waterways ripped out, lakes plowed under, wildlife poisoned.
Six months after the outbreak, the Resource Conservation District of Monterey County, CA conducted a survey of produce growers on California's Central Coast. Eighty-nine percent of respondents indicated that they actively discouraged or eliminated wildlife from produce fields in order to meet food safety requirements. Thirty-two percent of responding leafy-greens growers reported actively removing non-crop vegetation from their land due to comments by food safety auditors. Recent research conducted by the Nature Conservancy found that between 2005 and 2009 13.3 percent of the remaining wetlands and riverside habitat in the Salinas Valley were eliminated or degraded.
We Need YOU to Make Comments to the FDA Too!
WFA wants to make sure that this scientifically questionable, food-safety-inspired destruction doesn't spread to the rest of the country. The FSMA rules should reflect the 'co-management' of food safety and conservation---practices aimed to reduce food safety risks through methods which also minimize or avoid impacts to water quality, wildlife and habitat. As mentioned above, we found problems in the proposed FSMA rules concerning wildlife, domestic animals and soil amendments. On the flip side, we found good aspects of the rules that we would like to make sure end up in the final rules that become law. As the weeks progress we will provide you with more information on our analysis, as well as tools to help you make your own comments to the FDA.
Food Safety Modernization Act (FSMA):
- FSMA and Why It Matters**
- For Farmers: Will I be affected by FSMA?**
Co-Management of Food Safety and Conservation:
Learn more about the co-management of food safety and conservation through WFA's "Farming with Food Safety and Conservation in Mind"publication.
**Courtesy of the National Sustainable Agriculture Coalition