Sunday, November 21, 2010

Food "Safety" Act is Really the Food TAKEOVER Act

The S-510 Food “Safety” (Takeover) Act

S-510 – Food Safety Modernization Act – Here are some of reasons why the bill must be stopped. 

·         S510 effectively implements NAIS (National Animal Identification System)  for everything.
·         Tremendous amount of additional enforcement (fines and penalties, license revocations, further license requirements, control over processes and harvest).
·         FDA is instructed to follow all international agreements, including ‘guidelines and standards’ like GAP. Most GAP certifying bodies have checklists about 25 pages long for growers to follow. They all require traceability (i.e., NAIS) they also require auditing, verifying and certifying the processes used to produce a consumable product for human or animal feed. Every step in GAP costs the grower of food money and a good deal of paperwork. What happens if you’re better at growing food than filing forms? You will be penalized (i.e., more money).
·         It subjects all farms that produce milk to risk assessment and management.
·         The idea that exemptions will be helpful is rose-colored-glasses thinking. Exemptions can easily be taken away or modified without Congressional oversight through the regulatory process. Most farmers aren’t watching the Federal Register.
·         Redundant authority and abuse of power: FDA has authority to protect the anonymous food supply already. But they don’t. Instead, they put small entities out of business through Hazard Analysis & Critical Control Points (HACCP), also to be expanded in this bill, and heavier regulations that are not helpful to smaller economies of scale. The FDA inspects less than 1% of imported produce, has performed inspections on less than 25% of processing facilities that they are authorized to inspect (in a five year period) and they ALREADY have authority over live food animals on the farm. The USDA authority is over animal disease.

Each of these points puts undue regulatory burden on small, local and organic farmers. Note that the incidents of food contamination that made the papers recently all were from Big Agra/Big Food producers: Melamine in imported Chinese milk products; E Coli on CA spinach; hamburger meat. None of these incidents stemmed from sources on small, local or organic farms, which statistically are run more cleanly.

This bill does not address the real causes of food contamination: sloppy import practices, lax and uneven application of FDA and USDA regulation, introduction of genetically modified organisms, and intrusive subsidies.
This bill clearly represents government takeover (by excessive, unhelpful and unnecessary intrusion) into one of the most essential functions of human beings – growing and consuming food.

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