Dirt Eaters

Work, Food, and Communal Transformation

(from the frontlines of a hopeful revolution)

By the People, For the People

It been but two weeks since leaving the technocratic dreamscape of Washington DC, and already I'm a full-fledged member of the Tea Party.

Okay, not quite. But man, I get it. The shutdown is dumb and destructive, but those Libertarians weren't wrong about everything.

I was going to write this week about how the rhythms of work transform the mind, how they stress and strengthen a community. Maybe I would write about our forest walk and the saw mill, about turning the bounty of a healthy forest into simple and durable structures. Maybe I would write about the ridiculous trip we took with our new dairy cow, Goldie, from one end of the property to the other, and the magic drudgery that is hand-milking. Maybe I would write about a morning of intimate interaction with the pigs and sheep. Maybe I would write about harvesting carrots and cabbage and beets and turnips, about putting a farm to sleep at the end of the season.

Maybe I'll write about all of those things still. But my week's intellectual journey was derailed when I learned that my small farm dreams may die before ever being born. And the misguided good intentions (if we're being charitable) of new food safety regulations are squarely to blame.

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In a previous life I thought I wanted to work in public policy, maybe even food and agricultural policy. I saw the power of government to directly impact lives and businesses, to create space for some things to flourish, to make it impossible or impractical for other things to survive. What those things were depended on us the citizens, on our collective values, and on the intelligence and integrity of government professionals. I believed in the abstract wisdom of the citizenry, and I wanted to add one more (hopefully) intelligent and (mostly) ethical person to the policy mix.

It didn't end up being the right work for me, but this week I'm reminded of how grateful I am that it is the right work for other good people. I'm reminded of how reliant I am on them, how interwoven I am into this society of ours.

There's a lot of great writing out there on the Food Safety Modernization Act (FSMA) and the dangers it poses to the viability of small farmers and sustainable agriculture. I've been devouring the summaries and analyses put out by Brian Snyder (Executive Director of Pennsylvania Alliance of Sustainable Agriculture), the National Young Farmers Coalition, the Carolina Farm Stewardship Association, and the National Sustainable Agriculture Coalition. I can't and won't try to do them justice here, but I will post some links at the bottom, and if you care about where your food comes from, they’re each worth reading in full.

But I will say that - at a time when interest in local and sustainable agriculture is growing rapidly, when a revolution is taking hold in how we view nutrition and the role of bacteria in the health of all things, and when more than ever young people are returning to the countryside to work the land and try to earn an ethical living - the proposed rules put out by the Food and Drug Administration (FDA) under FSMA are truly shocking.

Signed into law in January 2011, FSMA gave the FDA broad powers to design new rules and regulations to prevent food safety problems. Earlier this year, the FDA released 3,500+ pages documenting those proposed rules. The period for public comment has been twice extended, with the final deadline now being November 15. Once the draft is made final, we will collectively have to live with the consequences. And all indications are that those consequences will be huge for small-scale and sustainable agriculture, for young and beginning farmers in particular.

The FDA’s own economic impact survey estimated that the average farm with annual revenues of less than $250,000 will lose over half of their (modest) net income each year to stay in compliance with FSMA. It should be noted that 96% of farms run by beginning farmers (those with less than 10 years of experience) gross less than $250,000 per year. So, that’s me and all my new friends here at the Farm School.

The FDA itself says that “the rate of entry of very small and small [farm] businesses will decrease.” Yeah, I’d say so. I assume that the FDA’s estimates are conservative. I am terrified.

These rules touch every aspect of growing and harvesting crops. (They only focus on produce, as livestock production is regulated by the USDA, who wrote new slaughterhouse regulations during the 1990s that resulted in many small processors going out of business, significantly hampering the local and ethical meat industry to the benefit of larger factory-farm style operations.) They mandate specific worker hygiene and training regimens, expensive weekly groundwater tests, and manure/compost application schedules, among other things.

They have the potential to make many food hubs - a new business model, near and dear to my heart, that has the ability to transform the local food marketplace by allowing small farmers to achieve the benefits of scale while retaining the benefits of being small and diversified - shut down, and prevent new ones from opening. Firms with less than 20 employees produce just 4% of the food sold in the US, but those firms would bear 73% of the cost of implementing FSMA’s new rules.

Again, this is according to the FDA’s own study.

Former USDA Deputy Secretary Kathleen Merrigan, a champion of local food and the author of the “Know your Farmer, Know your Food” campaign, stated in a recent speech that the FSMA rules have the potential to “destroy some operations.”

These rules disproportionately impact the sector of the food economy that is the least responsible for imperiling the food system. They appear to be ignorant of how small and diverse farms actually work. They are often based on discredited or outdated science. They contradict the government’s own organic program. They could halt innovation and reduce access to fresh and healthy food. They are frequently confusing and vague, and give far too much power to government regulators. They fly in the face of the everyday decisions made by a growing number of consumers (and citizens) who buy from small and local producers. They imperil the future of our food supply by discouraging young people from entering the profession. They say nothing about genetically engineered crops, pesticide use, or antibiotic resistance.

Like many in my generation, I think, the Iraq War made me profoundly disillusioned. Those in power were going to do what they were going to do. Protests, chants, marches, signs, letter-writing campaigns: none of it mattered. I might as well try build something I can believe in, to create something worthwhile, instead of fighting losing battles.

But I can’t just move to the countryside, immerse myself in physical labor, and ignore all the rest. Larger forces have a way of showing up on your doorstep, no matter what. Sometimes, you’ve got no choice, you have to fight.

I’m going to fight.

This is my future we’re talking about. Rather, this is our future. Public comment remains open for another month, until November 15. If you care about local and sustainable agriculture, please do something, anything, to help stop these rules from becoming the law of the land.

It is our government, after all. Let’s do whatever we can to make sure it reflects our values.

Let’s fight. Share your voice.

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To see pictures from what we actually did at Maggie's farm this week, click here...

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