Page 82 - Spring2010
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TAKE ACTION ON THE PROPOSED FOOD SAFETY BILL S 510

                       Call both of your Senators. You can find their contact information at www.Senate.gov, or call the Capitol switch-
                   board at 202-224-3121 or toll-free at 877-210-5351. Ask to speak with the staffer who handles food safety issues.
                       Tell the staffer that you want the Senator to amend or oppose S. 510. Engage the staffer in a discussion about
                   the importance of local, nutrient-dense foods to you and your family, and why your local food sources should not be
                   subject to FDA regulation. If you get their voice mail instead of the staff, leave the following message:
                       “Hi, my name is _____ and I live in ______. I’m very concerned that S.510, the FDA Food Safety Modernization
                   Act, would impose unfair and burdensome regulations on local food sources, which are very important to me. The
                   Committee version of the bill does not address my concerns, and I urge the Senator to amend or oppose the bill. Please
                   call me back at ____________.”
                       You can also send an email through the Western Organization of Resource Council’s automated system http://
                   org2.democracyinaction.org/o/5706/p/dia/action/public/?action_KEY=1775

                   TALKING POINTS
                   1.   The major foodborne illness outbreaks and recalls have all been caused by the large, industrial food system. Small,
                       local food producers have not contributed to the highly publicized outbreaks. Yet S. 510 subjects the small, local
                       food system to the same, broad federal regulatory oversight that would apply to the industrial food system.

                   2.   FDA regulation of local food processors is counterproductive and unnecessary. FDA has not used its existing
                       authority well. Instead of focusing its resources on the problems posed by imported foods and large processing
                       facilities, FDA has chosen to target small processors. While approving unlabeled GMOs to enter our food supply,
                       it has interfered with the free choice of informed adults who want access to this healthy food. Simply giving FDA
                       increased authority and power will not improve the food supply unless Congress requires the agency to focus on
                       agribusiness and not small, local producers.

                   3.   Relying on HACCP would harm small processors. Increased regulations and record-keeping obligations could
                       destroy small businesses that bring food to local communities. In particular, the reliance on HACCP (the Hazard
                       Analysis and Critical Control Point system) would harm small food producers. Although the theory of preventa-
                       tive controls is a good one for large, complex facilities, the federal agencies’ implementation of HACCP, with its
                       requirements to develop and maintain extensive records, has already proven to be an overwhelming burden
                       for a significant number of small, regional meat processors across the country. In the meat industry, HACCP has
                       substituted paperwork review for independent inspections of large meatpacking plants, while punishing small
                       processors for paperwork violations that posed no health threat. Applying a HACCP system to small, local foods
                       processors could drive them out of business, reducing consumers’ options for fresh, local foods.

                   4.   FDA does not belong on the farm. S. 510 calls for FDA regulation of how farms grow and harvest produce. Given
                       the agency’s track record, it is likely that the regulations would discriminate against small, organic, and diversi-
                       fied farms. The House version of the bill directs FDA to consider the impact of its rulemaking on small-scale and
                       diversified farms, but there are no enforceable limits or protections for small diversified and organic farms from
                       inappropriate and burdensome federal rules.

                   5.   S. 510 favors foreign farms and producers over domestic. The bill creates incentives for retailers to import more
                       food from other countries, because it burdens family farms and small business and because it would be practically
                       impossible to hold foreign food facilities to the same standards and inspections. The bill would create a consider-
                       able competitive disadvantage for all U.S. agriculture and food production (see analysis at http://ftcldf.org/news/
                       news-20Oct2009-2.html).

                   6.   Food safety and security both come from a diversified, vibrant local food system. Local foods give consumers
                       the choice to buy from producers they know, creating a transparent, accountable food system without federal
                       government oversight. State and local laws, which are often size-specific rather than one-size-fits-all, are more
                       than enough for local food producers.



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