Beginning farmers start small. USDA data shows that 96% of farms run by farmers with 10 years or less experience have annual gross revenues less than 250,000. The average achieve net income to US farms is 10% of sales, and so is less than 25,000 for almost all beginning farms. Beginning farmers face many challenges: They are less likely than established farms to inherit land or buy it from a relative; less likely to receive government payments; and more likely to have difficulty obtaining credit and financing land purchases. And now the federal Food and Drug Administration (FDA) is piling on new challenges in the form of its proposed regulations implementing the Food Safety Modernization Act (FSMA).
According to the FDA, the average annual cost to comply with FSMA’s produce safety rules for farms grossing less than 250,000 per year will be 6% of revenue. Do the math, and then ask yourself why anyone would choose to start farming—to endure 12+ hour days, have an extra job off the farm, face crop loss risk—when the federal government is promising to take more than half the profits. It may be the understatement of the year when FDA, in an economic impact analysis, says that “the rate of entry of very small and small [farm] businesses will decrease” as a result of the produce rules.
Just as overwhelming is the companion proposed rule on fresh produce handling and other food processing. This rule treats local food hubs the same as 499-employee manufacturing plants, with disproportionate requirements for record-keeping and sanitization. Even though firms with 20 or fewer employees produce just 4% of the processed food sold in the US, those size firms with bear 73% of the cost of implementing FSMA’s preventive controls, according to FDA’s own analysis.
In other words, the food hub movement will also be shut down by FSMA, cutting off a critical market channel that allows farmers to scale-up while retaining a significant share of the value of their crops. And beginning farmers are especially vulnerable to the loss of this sales outlet.
Other hazards in the rule–
- if you apply raw manure to a field, you’ll have to wait 9 months before harvesting any crops from that field.
- if you irrigate with surface waters, you’ll have to test that water once per week, or treat it with chemicals.
- if you grow crops in a hoophouse, you’ll have to keep the floors clean!
- if you are a food hub and you put labels on bags of raw produce, you are a ‘manufacturing’ facility.
We are not the only ones concerned about all this. Former USDA Deputy Secretary Kathleen Merrigan, a champion of local food and organic farming, stated in a recent speech that the FSMA rules have the potential to “destroy some operations.”
If we are to change this dangerous trajectory, we have to speak out. Food safety crusaders are running a well-funded campaign to clamor for even more stringent rules, despite the devastating impacts it will have on producers of healthy local foods. The deadline for comments on the rules is Sept. 16, so we’ve got just three months to make our voices heard.
TAKE ACTION - Comment on the FDA Proposed Rules Today
Together, we can prevent this train wreck, and ensure that local, organic agriculture—and beginning farmers—can continue to grow and thrive, and feed our nation healthier, better food.