Friends, Subscribers, Countrymen and Countrywomen…the time has come.

In just a few weeks, the US Food and Drug Administration will close the comment period on the regulations governing the growing of fresh fruit and vegetables, also known by the unfortunate misnomer “the Food Safety Modernization Act.”

This is your chance, as a eater of local and organic fresh produce, to tell the FDA what you think about their misguided efforts to keep you safe.

Do you support action by the government that cements the positions of Walmart and Costco as the primary source of fresh food for all Americans?  Do you support regulations that make it difficult for any but the largest farms to grow this food?  Because the regulations create numerous bureaucratic and economic barriers for small and medium sized growers.  You could say that this would be the “unintended consequence” of the new rules, except that the FDA freely admits in the prequel to the regulations that they will likely push many growers out of the produce business.

As written, the regulations would also impose new restrictions on organic farmers.

It is a simple fact that the vast majority of all the reported fresh produce-related illnesses in the country have been associated with produce grown on large farms, shipped nationwide, and eaten a week or longer after harvest.  This is the problem — the naked emperor, the elephant in the room.  The FDA rules should recognize that a viable local food production system is part of the solution.  Instead they do the opposite.

In its regulations, the FDA does not focus in on the crops, practices and the producers that are most likely to cause illness — otherwise known as a “risk-based approach”.  It lumps together crops like spinach and cantelopes that have caused large outbreaks of illness, with others that never have and are extremely unlikely to do so.  In doing so, it decreases its effectiveness.

Lastly, it focuses on farming practices that have never been scientifically proven to cause illness.  Irrigation water, for example. And since there is no science there, the solutions that are offered are equally unscientific.  There is no guarantee that they will stop a single person from getting ill.

If you are interested in contributing comments to the FDA but aren’t sure what to say, here are the suggestions from California Certified Organic Farmers, who are working with a coalition of other organizations to mount a unified response:

1)  The draft regulations should not make it more difficult and costly for organic growers to use farming practices that have never been connected to illness.  This unfairly targets organic farmers and will result in higher costs for organic eaters without any guarantee of safer products.

2)  The draft regulations include a number of rules that are not based on valid, peer-reviewed scientific research.  More research is needed on what the primary causes of contamination of fresh produce to help guide and focus the regulations.

If you are interested in adding comments based on your support of locally grown produce, you could add the following:

3)  The draft regulations should not make it harder for small and medium sized growers who provide locally grown fresh produce to compete with large growers and large chain stores — the responsible parties for the majority of documented outbreaks of food-borne illness.

4)  The draft regulations should acknowledge the growing preference by eaters (such as yourself) for locally grown food, which is a result at least partially of dissatisfaction with the freshness, quality and healthfulness of produce grown on a large scale and shipped great distances. 

While the Comments site may seem like a great place to editorialize on the faults of our food system and the FDA’s role in it, it is probably best to keep your comments short and to the point.  It is in everyone’s interest for the agency to take local and organic supporters’ concerns seriously.

Commenting on the rules is easy.  Just go to the website on the regulation, hit the “comment now” button and type in or cut and paste.  The comment period ends November 15.