Good Agricultural Practices (GAP) regulations on small farmers.

[fasttense]

As small farmers, most of you are probably familiar with the GAP regulations being proposed.

If not, below is a link that outlines the regulatory requirements being considered.

http://www.fda.gov/Food/GuidanceComplianceRegulatoryInformation/GuidanceDocuments/ProduceandPlanProducts/ucm064574.htm

I have some serious problems with these regulations and I think most small farmers will also. It is these burdensome regulations and accompanying fees that are driving the small farmers out of business.

1. The documentation required to satisfy an auditor or inspection. It is extensive and detailed and could take as much time as filling out tax forms. Unlike ConAgra, we can't just write a field number down and say we planted hundreds of pounds of all the same seed, and fertilized it with all the same chemical and sprayed it with all the same insecticide. I plant 14 different types of fruit and vegetables and the organic methods I use are diverse and constantly changing. The burden on most farmers for the maintenances of extensive records can take two or three days out of a week to keep up with.

2. The requirement to keep wildlife out at all times. Does anyone honestly believe ConAgra keeps all those birds from flying over or landing in their fields? Do you really believe they keep all the rabbits and deer out? Yet we as small farmers must spend hundreds to thousands of dollars on fencing and netting to attempt to comply with this regulation.

3. Fees. I have a serious problem with paying for my own inspection. It seems to me to be more like a bribe. I'm footing the bill, the inspector knows that and he will mostly likely side with the person paying his way. I know big corporations like it because it has a built in conflict of interest on the inspector's part. But these constant fees on a small farmer can become very burdensome and wipe out the small profits we usually make.

If you agree, please cut and past this letter and forward to your Representative and Senator. They need to hear from us small guys as well as the huge corporations.

Dear ___________,

I am a small-scale farmer living in _______ County in ______. I raise __ on my farm. I market my __ through _______________________ I market my through
When people hear the words “food safety.” It is something everybody wants. No one wants their food contaminated. However, the currently written “Good Agricultural Practices (GAP)” are an unreasonable burden on small scale producers like myself.

It is common sense for people who work on small farms to follow basic standards of cleanliness, such as washing hands before going into a field to harvest produce and after using the bathroom. I have no problem following these practices and reminding anyone working for me or helping me to follow these practices. But, many of the requirements of GAP are hugely burdensome and frankly, unrealistic.

The paperwork and the documentation of every farming practice right down to tractor maintenance is excessive. I am unclear on how a GAP auditor will handle livestock being raised in the vicinity of my vegetable growing operation. For instance, what constitutes a manure pile? Asking me and my neighbors to not raise animals nearby is not practical in ______________ where almost every farm has some type of livestock. Even more impossible is controlling wildlife. As you know, wildlife is abundant in ______________ and gardening in an area where wildlife lives is already challenging. Keeping wildlife out of the garden or from flying over the garden is simply impossible.

Please know that my family and I are working as hard as possible to produce high quality food for our own and the publics consumption. We take this work seriously and grow food carefully. Please offer amendments to make any food safety legislation work for small-scale producers. For example, allow reasonable buffer strips between livestock and garden areas (the Natural Resources Conservation Service requires a 30 foot wide buffer strip between livestock areas and natural water sources). Additionally, please remove wildlife from the food safety equation. Remember that for thousands of years food has grown and has been produced in the vicinity of animals. Our population has thrived on this food.

I understand that costs are associated with inspections. But passing the cost on to a small farmer and their family could be the difference between making a profit that year or not. The payment of fees to an inspector sets up a conflict of interest. If I pay the inspector a fee wont he be more likely to decide in my favor? Payments like these sound more like bribes. If they are necessary, than spread the cost around to those who can more easily afford them. Those who are being inspected should NOT foot the bill for the inspection where a conflict of interest would occur.

Your help in ensuring the survival of the small farmer will be an important step in preserving our nation's food supply.

Please feel free to contact me if you have any questions.

Sincerely,

[yellowcanine]

1. These are NONBINDING recommendations for industry from 1998.

Guidance for Industry: Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables
Contains Nonbinding Recommendations
October 26, 1998


They are not "GAP regulations being proposed" - at least, the link which you provided is not about regulations being proposed in 1998 or now. Regulation is indeed a burden on small farmers but please let's not "cry Wolf" lest people not listen when there is a real issue needing our attention.

Currently in the U.S. GAP and third party audits are something that wholesalers and retailers, such as grocery stores and restaurants, are requiring of farmers who supply them fresh fruits and vegetables - not something being proposed as regulations by a federal government agency, at least I have not seen any such proposals. If you have a link to such a proposal I certainly would be interested in seeing it - the link you provided is not a proposal for regulation.

The e coli in spinach incident in 2006 which nearly destroyed the spinach industry in the U.S. was possibly caused by wild pigs getting into an organic California spinach field, according to resulting investigations. The wildlife issue is no small thing. You can say that following basic standards of cleanliness is all that should be required and anything beyond that is unrealistic or impossible but that view is what is unrealistic. Whether in that case it really was wildlife, the science shows that e coli can show up on spinach in fields even before a single worker has entered the field to harvest the crop. And washing will not remove e coli from leafy vegetables such as spinach. If you want to know more about this, check out the work of Dr. Chris Walsh at the University of Maryland. He has done some interesting work on this topic. http://www.psla.umd.edu/faculty/walsh.cfm#research

Link to spinach story.
http://www.usatoday.com/money/industries/food/2007-09-20-spinach-main_N.htm

[yellowcanine]

2. To be a little more specific, this is what is known as a Guidance Document

Guidance Documents are meant to be just that - offer guidance. They are not regulations or proposed regulations.

There is a footnote that spells it out:

"This document has been prepared as guidance by the Food and Drug Administration (FDA) and the USDA. This guidance represents the current thinking of FDA and USDA on a number of microbial food safety hazards and on good agricultural and management practices common to the growing, packing, and transport of most fresh fruits and vegetables. It does not create or confer any rights for or on any person and does not operate to bind FDA or USDA or the public. The agencies encourage growers, packers, and shippers to use the general recommendations in this guidance to tailor food safety practices appropriate to their particular operations. An alternative approach may be used if such approach would effectively serve to reduce microbial hazards that could result in foodborne illness and if such approach satisfies applicable statutes and regulations."

[fasttense]

11. Congress is currently considering establishing inspection requirements.

See this link. http://www.govtrack.us/congress/bill.xpd?bill=h111-759&tab=summary

There are more.

It is currently being discussed in the house and my Representative discussed using GAP procedures as a basis for the law when my co-op met with him about 3 months ago.

I don't believe most people would want to wait until the law passes to let their Representative know how they feel about it.

The link I originally provided was to a description of what GAP is.

Yes, they are voluntary for now.

Wild pigs destroy plants and tear up the ground as they forage. I wonder why the farmer used that half destroyed crop? I would have called it a loss. You know it had to have been dug up and half eaten. Since organic certification is so expensive, he probably tried to use as much of the destroyed spinach as he could.

And there in lies the problems. If the farmer was not so absolutely concerned about making a profit (partly due to the expense of certification) or if profit margins were not so restrictive with produce (thanks to corporate Agra-businesses), perhaps he would not have tried to use the trampled over spinach.

I went to your link but could find nothing specific about how to prevent wild animals from accessing farm areas.

My request was to simply let your congress critter know how you feel. If you don't agree, don't write him/her. Or better yet, write your congress critters telling them how much you love using GAP procedures.

[truedelphi]

23. Last year I interviewed a reporter for the SF Chronicle, and he had

Written a story about how some of the local farmers here in California went out and tore up their crops to replant due to these guidelines.

Mind you, they were not FORCED to, with a gun to their head, but they felt that they had a better chance of fulfilling existing contracts if they did so.


It is now a deplorable situation - let a bird land on your crops, and if some "inspector sees it, your field may be one that no one in the food industry can accept crops from.

meanwhile, the large and awful expanse of land from Williams Calif to Sacramento - that area where all that you see are over pesticided farm land, no trees, no wild life, etc that is the nightmare that we are being faced with. The air over this farmland smells like adhesive factories, or paint thinner factories are in the area - if you smelled a bottle of the air from this area, the notion that it is farmland would never occur to you.

I remember the farmlands of my childhood, and this is not what farmland should smell like.

But no matter who or what we vote for, Big Agri industry gets ahead and the small farmer gets totally F__k__!

[fasttense]

24. Food safety bills written by Monsanto.

http://www.opednews.com/articles/Goodbye-farmers-markets-C-by-Linn-Cohen-Cole-090303-287.html

"The "food safety" bills in Congress were written by Monsanto, Cargill, Tysons, ADM, etc. All are associated with the opposite of food safety. What is this all about then?

In the simplest terms, organic food and a rebirth of farming were winning."

The operative word here is WERE.

"To wit, they (CONAGRA) must get rid of such good and innocent things and yet truly powerful things as: Farmers markets. Local farmers. Real milk. Fresh eggs. Vegetable stands. And how will those who contaminate our country's food with pesticides, hormones, antibiotics and more, do that? Why, by setting standards for "food safety" that are so grotesquely and inappropriately and even cruelly applied to a local, independent farmers and ranchers that there is no way they can manage.

"And how did they get this far with such a scheme to apply insane industrial standards to every farm in the country? Through fear of diseases and of outbreaks of food borne illnesses, both of which they cause themselves."

"The bills would require such a burdensome complexity of rules, inspections, licensing, fees, and penalties for each farmer who wishes to sell locally - a fruit stand, at a farmers market - no one could manage it. And THAT is the point. The whole dirty tricks point. The whole "be in tight control of everything needed for survival because it'll be worth a fortune"."

Read and heed:

Goodbye farmers markets, CSAs, and roadside stands.http://www.democraticunderground.com/discuss/duboard.php?az=view_all&address=103x532087

For those who thought my warnings about GAP were not a real concern, you should read the links. It's sad, very sad.

"But we need to stop these bills first or we are left with no money from the financial bailout and no food from the food stealout."

Send a message to Congress. Let Congress know how you feel about this ridiculous laws they are about to burden us all with.

"We need millions to be fighting this. Contact Eli Pariser at MoveOn [e-mail] to tell him MoveOn is badly needed.

And below, where Oped News offers a means of writing your local newspaper, take advantage of a chance to vent."

[truedelphi]

25. Not so. There is both a Senate bill in the works, and there is also

The FDA group out on the road with new proposals, pretending that they give a crap about what small farmers think. (comment period for the new FDA regs expires sometime later this month.)

Last year, The Chronicle already had stories about farmers who had to plow up planted crops, as some inspector came by and saw for instance, a bird land twenty five feet from the row of corp.

I actually talked to people in the article and to the reporter, at that point in time. And in a sense, the situation was "non-binding" except if your specific contract was with someone who had a "standard of excellence" that they would only buy from people observing these regulations, you as a farmer had better dig everything else or be responsible for monetary damages.

These new regulations will be binding. And it is not based on science - because if it was, the FDA would admit what most of us already know: the majority of food poisoning cases in this country exist by and large because of the way people handle food in their homes and in the restaurants and delis. Remember the e coli outbreak when Jack in the Box decided that 135 degrees was hot enough to kill off e coli?

I had neighbors who used to defrost their chicken in fridge shelf above their lettuce, and no matter how many times I explained the non-wisdom of that, they would do it. Then they would visit me a week later and mention how many people got sick at their BBQ.

Small farmers are realizing that if these new regulations take effect - a massive change will take place. Ponds may be required to be filled in, so birds cannot migrate over the pasture and use their usual habitat.

Groves of trees may be required to be cut down - as the birds and other animals that live therein will no longer be welcome on the small farmers' lands.

This is basically a holocaust for wildlife, for the environment, and for those of us who maintain our health only because we eat 100% organic.

However, it doesn't make much difference to the larger corporate farms - they already do all those things. Drive from Williams Calif. to Sacramento some time. You can count the groves of trees on two hands. You can smell only the smell of pesticides, and other noxious fumes.
And you see no wildlife!

[bvar22]

3. Thanks.

When I look at these regs, I just laugh.
We currently don't "market" anything, but will in the near future.
At this time, our surplus is given away to neighbors feeling the economic squeeze, or bartered for other services, but we are expanding.

We'll be registering our Veggies, Berries, Fruit, and eggs, and submitting to inspections right after we register our guns.

We have made one exception.
We keep Honey Bees, and have registered our hives with the state, and submit to annual inspections.
In THIS case, the benefit far outweighs the harm.

[yellowcanine]

4. These are not regulations. This is a 1998 guidance document.

In fact, if you want to sell fruits and vegetables to many wholesalers and retailers, following GAP practices and getting a 3rd party audit is required. They won't buy them from you otherwise. If you want to sell fruit and veggies by the roadside or at a farmer's market you will probably not need them. Eggs can be a little trickier, depending on the jurisdiction.

[bvar22]

5. Yes. I read your post.

I still find them laughable, even as "recommendations".

[yellowcanine]

6. I see nothing laughable about deaths from e coli on spinach in 2006.

Which were avoidable had the company in California followed the recommendations - as they had agreed to do in their agreement with the wholesaler. Because they didn't not only did people die but the whole spinach industry took a major hit. If you are going to be in the business of selling fresh fruits and vegetables you would be wise to read the recommendations again and take them seriously. The farmers I work with do and frankly I would not buy fresh fruit or vegetables from anyone who didn't.

[bvar22]

7. There are so many problems.

At one time, the FDA was able to do a pretty decent job at regulating agricultural commerce, and enforcing minimum standards in the US.
Then along came NAFTA.
How are these "standards" going to be applied in Mexico?
That won't be happening.
How will you ever know if the Lettuce you just bought was grown in a Mexican sewer, trucked across the border, and packaged in the US?
Chinese Veggies are even MORE problematic.
This will simply be another burden to American farmers unless our Trade Policies are completely rewritten.

Produce in local "Farmers Markets" can be even more toxic than what is on the shelf at the Super WalMart. Some small scale farmers WILL use MORE pesticides, herbicides than commercial operations especially if their small crop is threatened...and tell you to your face that "Sure. All my stuff is organic".
It happens.

The reason I found it "laughable" were pointed out in the OP.
Do you find it feasible to keep "life" out of your fields or gardens?
Would you really want to?
I find the concept of an antiseptic garden a grossly humorous Contradiction of Terms.
(I laughed again as I typed that.)
Our garden is filled with LIFE from below the ground to above the top of the highest sunflower....as it should be.
Every single critter produces "shit"...as it should.

As far as your spinach goes, I suggest you wash it before you eat it, especially if you don't know where it came from. We frequently eat while in our garden, and I guess I have ingested e coli from time to time (birds?), but we don't use raw manure. We eat our own food, and behave accordingly.

The point is, the entire Corporate Factory Food Production & Delivery System is thoroughly contaminated (with things far more toxic than E Coli). The "regulations" posted above aren't going to change that.
My wife & I felt so strongly about this issue that we moved to The Woods in 2006 and started growing our own. The only way to know for sure is to grow your own.

I laughed when I read the regs simply because they are a spit in the wind.
I said, "Well, thats not happening here,"
Which is the very same thing most people who grow their own food will say.


....if for the taste only!

[yellowcanine]

8. Washing spinach will not remove all e coli.

The fact that veggies from other places may be contaminated is no reason for ignoring GAP in our own production. Yes people will still ignore the recommendations but that is no reason for not trying to follow them ourselves.

There are things we can do. It is possible to minimize wildlife access to the most vulnerable crops such as leafy vegetables.

You still allude to these recommendations as if they were proposed regulations. They aren't.

Commercial vegetable growers in other countries have to follow GAP in order to export their products. Will things slip through? Of course. Is that a reason for throwing up our hands and saying, "What the hell, it is like spitting in the wind." No.

Because it is alive or from a living thing doesn't mean you should be eating it. That is a romantic notion that has no scientific basis. Some of the most toxic substances come from living things. Aflotoxins, mycotoxins, curare, ricin, rotonone, botulism, e coli 1057:H7 to name a few. E coli 1057:H7 will kill you. It doesn't matter if there are things which are more toxic. Dead is dead.

If you grow your own and ignore these recommendations you can't be sure either.

[bvar22]

9. My goodness.

How did we ever survive as a species? :shrug:
Eating stuff that grows right out of the DIRT!!! Ewww.

I have no objections to the "recommendations", even the laughable ones.
Everybody who grows food should behave as if they are the ones who will be eating it.

Keeping big critters OUT of the garden makes sense if you want to have something left to eat.
Any attempt to keeping ALL animals OUT is impossible (and laughable).
Occasionally, a bird WILL shit in the garden.
Occasionally, a possum or coon WILL climb over the fence.
Mice, Volls, Gophers, Moles WILL find their way in.
The poisons used to eliminate THEM are way worse than the occasional pest.
The BEST way to deal with THEM, is a pair of good Mousers.
Occasionally, our mousers WILL poop in a raised bed.
No big deal.

In reality, we ARE very careful.
Hilltop location....no downflow contaminants.
Irrigation by on property Spring which we also use for drinking water.
We are very careful about what is allowed in our garden...or on the entire hilltop.
We use raised boxes, aged compost, and a dry straw mulch barrier between the fruit and the raw earth wherever possible.

We neither need, nor want, nor will cooperate with an "inspector" or provide "documentation" for anything we are growing on our hilltop. (I also find THAT image laughable).

We do not aspire to be a "commercial" operation, or a vendor at the Farmers Market.
Our main goal is to produce as much of our own food as possible.
We naturally have an overflow which goes to either neighbors or to the local Food Bank.
The nearest Farmers Market is much too far away to make it economically feasible,
though we are promoting a local effort among 5 or 6 neighbors to coordinate & combine harvests, and transport these to the nearest city. That is still in Talking Stage.

We do have plans to eventually market our own brand of sun dried BlueBerries, herbs, and Bee products.


The June Bearing Strawberries are blooming today.
It won't be long now.
I eat them right IN the garden!
YUM!
You are welcome to a handful, but you'll have to eat them in the garden.
:hi:

http://www.democraticunderground.com/discuss/duboard.php?az=view_all&address=268x2601

[yellowcanine]

10. Ever read Leviticus? The Jewish dietary laws were an early attempt to practice food safety.

We survived as a species because those of us who got careless died. The ones who survived figured out how to avoid bad stuff by paying attention when they got sick and avoiding that food or that way of preparing the food the next time. They passed the information to the next generation. That's how we survived.

[fasttense]

14. I have a problem with your analysis of the e-coli in spinach scare.

Wild pigs trample and dig up the fields as they travel and eat. Their destructive paths through cultivated fields can be easily identified.

Why did the California farmer decide to use this trampled crop?

I would have called it a loss.

He used it because of the expense of getting organic certification and the slim profit margins vegetable growing and selling provides.

Perhaps if we looked to reducing the expense or increasing the profit margin for small farmers than people would not try and reuse trampled spinach. Part of that expense is tied up in getting certification/permitting/registering. Reducing these costs may prevent future spinach problems.

In addition, the GAP procedures would NOT have stopped the organic farmer from using the trampled spinach. The odds are good that an inspector would not have been there at the time of harvest. The farmer could still have decided to try and salvage the devastated field of crops. The spinach problem will not be solved by more regulations. Unethical people are everywhere and no amount of regulation will stop them. Reducing their motivation to be unethical seems to me to be more logical.

[yellowcanine]

15. Pigs were cited as a possibility by the investigators, I don't know the details but

there were no reports of any trampling. The investigators did say that the farmer was not following all of the GAP requirements as required by the wholesaler.

Look you can try to rationalize this but GAP is a fact of life in today's fresh vegetable and fruit industry - NOT because of government regulation but because the wholesalers and retailers are demanding it to protect their customers and to protect themselves from lawsuits. Reducing the motive to be unethical and following GAP are not mutually exclusive. We should do both.

Oh and it wasn't just a "scare", by October 6, 2006 199 people had been infected, including three people who died and 31 who suffered a type of kidney failure called hemolytic uremic syndrome.

[fasttense]

16. I find the explanation of wild pigs alone to be suspicious.

It is interesting this case was from a supposedly organic farmer with a rented 50 acre field. The farmer had rented it from a cattle rancher and there were traces of the same e-coli in the fields and water on the cattle ranch.

As I said previously, the wild pigs would leave a clear and devastating path. Anyone with common sense would not have used the spinach in the field they had trampled through. Wild pigs do not gently go through a field and merely leave droppings. There is more to this story than simply wild animals.

Wild animals are everywhere. There is no way of ensuring they do not approach your fruits and vegetables unless you resort to extermination. I do not want to kill off all the frogs, reptiles, birds, deers and bugs that surround me in order to sell to a public that has become phobic due to the industrialized and inhumane procedures of big corporate farms. I do not exaggerate. There are farmers who are doing just that in order to meet GAP procedures.

Since you like following GAP procedures so much write your congress critter and tell him/her. You seem to be rationalizing their necessity more than most small farmers.

As for me, I find them to be too burdensome.

I don't mind following common sense practices as I stated in the sample letter of my post. But tracking and recording all my tractor maintenance? How is this tied to food safety? Killing off wild life to get certification when mankind has been living next to wildlife for centuries is excessive. Paying for, or more likely bribing, an inspector is just another method of ensuring that Only big Agra corporate farms can afford to sell food.

[yellowcanine]

17. It is not what I like or don't like. I am not rationalizing anything. I am telling you what

I have observed and what I have heard the scientists say who have worked in this area. I have no dog in the fight except that I am a consumer. I work for a university and I advise farmers. GAP is not being enforced by government regulators and there is no proposed regulation so why would I write Congress? How many times do I have to say that? It is being required by wholesalers and retailers. You present a skewed view of GAP from my experience. If you don't want to follow GAP, ok. But there is no need to slander third party auditors based on your dislike of GAP.

As for the spinach, no doubt there is more to the story. There nearly always is. But you don't know what that is anymore than I do. I told you what investigators found. Their conclusion about the pigs was not definitive. They said it was a possibility. They are the trained investigators who went onto the site and did the investigation. You aren't and neither am I and we weren't there so who are we to question them?

I can see why equipment maintenance records are important to food safety. Tractors and harvesting equipment can leak fluids which could contaminate produce and there might not be any way of knowing it until someone eats the contaminated produce and gets sick.

[fasttense]

19. So you are NOT a small farmer.

You wont have to follow GAP procedures. You will merely make others follow them or advise others to follow them. Your livelihood, your ability to pay the electric bill, will NOT depend on following GAP procedures.

There is a bill in the house to set up inspection of small local farmers. There are also several food safety bills being considered in the House that will inspect small farmers. The bills are using GAP procedures as their basis according to my Representative and to numerous national agricultural groups. Yet you dismiss my observation as if they did not exist. I would take your observations more seriously if you did not discount mine.

How am I slandering third party auditors? Hypothetical examples are not slander. My observations are based on solid examples from the everyday business world. It has been shown time and time again that when evaluators, inspectors and raters are paid by the institution or group being inspected, they tend to favor those who are paying them.

Look at the rating agencies for those sliced and diced mortgage certificates that started this Great Recession. They gave triple A ratings to junk. It happened because the people selling the junk paid the rating agencies. The rating agencies would lose business if they rated the certificates poorly. There are also numerous cases of mine inspectors certifying mines as safe when they were not because the owners of the mines were paying the inspectors for their inspections.

There is a built in conflict of interest the moment you allow the inspector to be paid by the inspected. We should learn from these examples and not merely shrug them off and say it can't happen to us.

We should always question the inspectors and always question authority. They are not infallible, they are not perfect. They are human and are subject to human vices.

Farmers have been killing off wild animals for centuries. The pesticides used on fruits and vegetables are just one example. Do we really want to set up procedures that encourage even more devastation to our wildlife? There has to be a better way. As smart as you are, I'm sure you can recommend procedures that do not encourage farmers to destroy wildlife and their habitats.

A simple check off list of say, "Are any fluids leaking from your tractor during operation or while parked" would be enough to cover possible leaks. Annual documentation of all tractor maintenance is a bit excessive.

If you have a hand in developing these GAP recommendations, can you develop less burdensome procedures? You seem to be intelligent and articulate. The 3 points I made about GAP "guidance" are not even a quarter of the guidelines, they are minor problems in a vast list. There has got to be a way to meet the need for food safety while improving on these 3 points.

I appreciate your passion for these guidelines and I understand your concern over food safety. I do not mean to minimize your expertise. I just know that there has got to be a better way to approach this. Maybe you are the one who can figure it out.

[yellowcanine]

20. I advise small farmers to help them to be able to sell their products and get a decent price.

If they blow off GAP as "too much trouble" it is going to be difficult for them to even be in the game. I have not had any hand in developing GAP, it is not my area of expertise. I am an Extension Educator - I work in pesticide safety education, nutrient management education and do a little applied research on alternative crops as well as help to coordinate programs where specialists with expertise in specific areas such as GAP can address farmers. The specialists that I talk to are adamant that GAP recommendations are going to be the norm for anyone who wants to wholesale fresh fruits and vegetables or sell directly to certain retailers (large grocery chains, restaurants). I am sure many of the guidelines seem burdensome for someone just starting out of someone who has been mostly doing on farm retailing or local farmer's markets. But if you want in the game you are going to have to play by the rules of the large wholesalers and retailers because THEIR customers are demanding it. Right now I don't see the federal government requiring GAP for small fruit and vegetable producers (though I think some states might) unless the industry continues to have major failures such as the 2006 spinach fiasco. Episodes like that have the potential to ruin it for everyone.

One observation I might have is that I find your resistance to something like keeping maintenance records on equipment puzzling. A good manager (Ag or not) keeps such records. The last thing a farmer needs is an equipment failure during critical times such as planting or harvest. And record keeping of all sorts is the difference between success and profit and failure and loss for a farmer. Planting dates and methods, harvest dates, pesticide applications, fertilizer applications, crop maintenance, weather, financial - all of these records are critical for both agricultural success and business success.

[fasttense]

22. Records do not pay the bills.

Having some inexperienced conflicted inspector coming out to look at my records wont pay my bills either. It will simply add yet another ridiculous level of supervision over me and take hundreds of dollars out of my pocket.

The only reason all these regulations are being pushed is because Corporations have people phobic over the inhumane, unethical and filthy methods Agribusinesses uses. Soon all small farmers will be forced to operate the exact same way that corporate farms do.

[fasttense]

13. The House of Representatives are currently considering inspection requirements for local small

farmers.

My Representative discussed with our co-op using these GAP procedures as a basis.

Yes they are voluntary for now. I did not mean to give the impression that these GAP procedures were currently regulation. My apologies if I misstated the issue.

I see you like the GAP procedures and don't mind the fees, inspections and documentation requirements. So, perhaps you should write your congress critter and tell him how much you enjoy following GAP guidelines.

[yellowcanine]

18. What House bill is that because the document you linked does not propose regulations.

It calls for establishing science based minimum standards. It says nothing about requiring those standards of small farmers. All farmers should welcome a risk based inspection schedule. If they are doing things correctly it will prove that their produce is safe. If they are not they would want to know would they not?

[fasttense]

12. I love your line:

"We'll be registering our Veggies, Berries, Fruit, and eggs, and submitting to inspections right after we register our guns."

This year so far, I have spent $150 getting certified/permitted/ registered to sell vegetables. You would think I was selling live ammo.

[timo]

21. inspections a joke

I had to pay 25 dollars to get a card from the state to sell poultry and exotic birds (peacocks)!!!
The inspector pulled up in the driveway, talked about the nursery and tree farm saw a pack of guineas run by, signed off on permit and left.
I mailed it and the 25 dollar check and 14 days later I am a card carrying poultry seller!!!
He never looked at the pens, the brooder, where I was feeding broilers....I couldve had a chicken torture farm and he never looked at crap!!!
I went to another farm a few weeks ago to look at some peacocks....they were standing in mud and crap 6 inches deep, that lady had her card too?!?!?!!?!