I wanted to publish a thoughtful commentary submitted by Denise Donohue, executive director of the Michigan Apple Committee. Denise sent this to me in the week before Christmas when I was out and I didn't see it. The letter is in response to my column about food safety legislation.
I need to pause in my holiday merriment and respond to your November 29th editorial on the exemption for small farms in Senate Bill 510, now working through congressional technicalities on its way to becoming the law of the land.
“What’s it to You?” the headline asks the larger commercial grower. I’d like to lay out a few areas where equal regulation of “small” farms is critically important to the larger-scale produce industry.
Equal Scare Opportunity. There’s no question that a food safety scare caused by a small grower has a chilling effect on all producers of that commodity.
Consumers have demonstrated they cannot – or are unwilling to – differentiate between US vs. Mexican tomatoes, or between Roma and beefsteak tomatoes. Instead, they stopped buying all tomatoes for weeks on end in 2008. These consumers are certainly not going to buy large growers’ produce if a small grower causes a food safety incident. Everyone suffers.
Having started down the road of on-farm GAP, and GHP/third-party audits for packers and shippers – which makes an incredibly strong food safety statement to the public – US food safety policy should not excuse thousands of growers from meeting this standard. It’s a big step in the wrong direction.
This is also where Karst’s last-minute-worker-same-wages biblical parable falls apart: In the parable it was a simple inequity of wages that inspired jealousy. In real life, exempting smaller growers from GAPs and more goes beyond petty jealousies and could actually be a life or death issue.
False Impression. By excusing small farmers from meeting GAP and other food safety requirements, our government sends the inaccurate message that small growers are somehow inherently safer. In fact, small farms or small packing houses often lack sufficient staff and capital to keep abreast of the latest food safety regulations, procedures and equipment. (Of course, most small farms and packing houses do a stellar job – and wouldn’t mind meeting federal standards.)
Let’s address the point of “small farms,” which runs scarily close to the environmentalists’ “factory farm” language. Using the Michigan apple industry as an example, we have 900 growers and an annual “farmgate value” (the amount growers are paid for their apples) of about $130 million.