So, just when the country is awaking to the need to relocalize its food sources, we find that many meat processors who would serve this growing market have been forced out of business by vague, onerous and costly regulations imposed under the guise of food safety.
Do we want the same thing to happen to our produce growers? Do we want to hyper-regulate those farmers whose practices do not contribute to the food poisoning problems endemic to industrially produced food products and de-regulate those whose practices poison us? No? But that's what we're being set up for with the Food Safety Enhancement Act of 2009.
Déjà Vu All Over Again
FSEA's fake HACCP requirements will do to small and what's left of medium produce farmers what Taylor's meat and poultry fake HACCP rules did to small and medium meat slaughterers and processors.
Under HR 2749, farms, now redefined as "facilities," would be required to maintain extensive records demonstrating their compliance with standards and make these records available to auditors. If a facility's records failed to meet "performance standards," whatever those are determined to be, the food "grown, harvested, processed, packed, sorted, transported, or held under conditions that do not meet the standards," would be considered adulterated (Sec. 104 (a)). So, even if a farm's or "facility's" food was perfectly safe, it could be considered in violation of the act and subject to substantial fines and see its product confiscated, if merely some element of it's paperwork was out of order.
Does This Pass the Smell Test?
If HACCP is not appropriate for application to the farm as Dr. Sperber maintains, why is it being forced on farmers? Is this really all about food safety?
Why should farmers be subject to so many burdensome costs, from a non-progressive $500 registration fee to the costs of tracing technology and extensive, expensive testing technology? Why wouldn't Congress fully fund the program, relying instead on fees, fines, and criminal judgments to fund it, if it were serious about food safety?
One farmer with professional knowledge of what's required to create and maintain a HACCP plan says it would take him 100 hours to create a plan for each type of food processed plus two hours each production day to maintain it. Laboratory costs would be $15,000 just for microbiological testing.[30]
Microbiological testing isn't going to be the only business platform in line to profit from HR 2749's requirements. Forbes Magazine recently ran an article describing the bundle that will be made by businesses that make products to relieve consumers' fears. To satisfy the bill's traceability requirements, farmers may find themselves hit with a bill of $20,000 for tracing software. [31]
One of the few organization that is able to see the unnecessary hardships this bill would place on farmers is the Farm-to-Consumer Legal Defense Fund issues, which notes that the cost of implementing these proposed regulation would drive many farmers off their land and lead to further consolidation of the industry.[32]
Test This
Is this perversion of HACCP due to an innocent misunderstanding, lack of industry experience or incompetence? Or, is there something else going on?
If you follow some of Taylor's activities since he ceased (officially) serving as Monsanto's Vice President of Public Policy and the present time, you'll find that he's worked for no less than five think tanks, churning out policy recommendation and reports to support his vision of a global food system. He's also picked up an academic affiliation, becoming a research professor at the George Washington University School of Public Health and Health Services.
As Director of the Global Food Systems Program at the Resources for the Future, a highly influential establishment think tank, Taylor has steadily worked on projects that promoted certain policy recommendations for new food safety regulations, but it is acknowledged that food safety is merely one part of his larger concern. [33]
In a short 2002 report published RFF called "Reforming Food Safety: A Model for the Future" Taylor writes that "We operate within a global food system in which World Trade Organization (WTO) agreements have an important impact on the standards that govern both food imports and exports. To achieve its legitimate public health and economic objectives within this system, the United States must be an international food safety leader." [34]
