November ___, 2007

Docket Clerk

Marketing Order Administration Branch

Fruit and Vegetable Programs, AMS, USDA

1400 Independence Avenue, S.W.

STOP 0237

Washington, DC 20250-0237

 

Fax: (202) 720-8938

 

Dear USDA Agricultural Marketing Service:

 

RE:        [Docket No. AMS–FV–07–0090; FV07–962–1 AN]

              pages: 56678 -  56680, Federal Register/Vol. 72, No. 192/Thursday, October 4, 2007/Proposed Rules.

 

Thank you for the opportunity to comment on the proposed federal rules for leafy greens.  I am a (consumer, farmer business owner, chef - check which one when you sign)

Q. (1) I am opposed to the use of Marketing Orders or Marketing Agreements for food safety purposes. I am particularly opposed to an arrangement where a board of handlers and processors is given government-sanctioned control over farming practices on every farm in the country.

Q. (7) Neither the FDA guidelines nor the California Leafy Green Marketing Agreement (LGMA) metrics are appropriate for most family farms and they are hostile to many organic farming practices. I am concerned that the science needed to make effective rules regarding the spread of pathogens such as E. coli 0157:H7 is inadequate and making blanket rules is premature and costly.  There have already been two recalls involving signatories of the LGMA, showing that their “Good Agricultural Practices” do not solve the problem of E. coli 0157:H7 contamination. The LGMA metrics discriminate against certain types of biological farming and wildlife practices with no scientific justification.  I urge you to take biological practices into consideration in any proposed rules, since such things as wetlands and microbial diversity in soil have been found to reduce pathogens.

Q. (8) I believe that the USDA should limit the definition of leafy greens it is seeking to regulate to the high-risk, “fresh-cut” bagged salad products, and not include traditional whole leafy greens.  The current definition of leafy greens in the proposed regulations includes produce that has never been implicated in an outbreak such as chard, arugula and kale.  The vast majority of growers sell to the whole fresh market and have never been implicated in an outbreak or recall.  According to data from the US Food and Drug Administration, since 1999, 98.5 percent of E. coli 0157:H7 illnesses from leafy greens in California have been traced to fresh-cut salad in California. Traditional fresh market growers should not be regulated by rules designed for large-scale suppliers of the fresh-cut processing industry.

Q.(10) To comply with the California LGMA metrics would cost farmers tens of thousands of dollars. The water testing requirements are particularly onerous and excessive in many watersheds where pathogens are not widespread. Large growers have the personnel and resources to comply with such requirements and smaller family farms do not. If the USDA implements such rules for all leafy greens growers, it will drive many small and organic farms out of the leafy greens market and destroy the local food systems that the agency has been encouraging across the country.

Thank you for your consideration.

Sincerely,

 

Sign this letter to tell the USDA that you are opposed to using this model for food safety that could needlessly limit your access to traditional, fresh leafy greens from local growers nationwide! 

To see the entire Federal Register notice and the complete list of questions from the USDA,  click here.

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Click here to sign a letter to the California's leafy green industry demanding to keep your access to traditional, fresh leafy greens from local California growers!