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Provide Your Feedback on FDA Regulations That Could Impact Local Producers

I just finished submitting my comments on regulations.gov and to my legislators on FDA regulations that are under consideration right now and could dramatically impact small-scale providers of locally grown and produced foods.

Read the full details of the regulations and their potential impacts here on the Food Renegade blog.

I adapted the language on that site with my own comments and submitted it to regulations.gov at these links:

On-Farm Produce Rule: http://www.regulations.gov/#!submitComment;D=FDA-2011-N-0921-0199

Preventitive Controls/HARPC Rules: http://www.regulations.gov/#!submitComment;D=FDA-2011-N-0920-0188

I then sent the same comments to my federal legislators asking them to take my comments into account if they play any part in the process of finalizing such regulations.

Please consider doing the same thing. You can use my comments below:

As a consumer of locally produced food from farms in my area of the Eastern Shore of Maryland, I urge the FDA to address the following issues in the proposed FSMA rules. It is so important to make it EASIER for these small farms to operate, rather than throwing up hurdles and roadblocks.

Industrial agriculture lays waste to land that could feed local populations so much more easily, with less damage to the environment, and healthier food options for consumers. Save the onerous paperwork and inspections for the industrial-scale operations that are poisoning our land and our food with pesticides and GMO crops. Let the smaller-scale producers flourish.

Tester-Hagan “qualified exemption” in both the Produce Rule and the Preventive Controls Rule:
The gross sales test to qualify for the Tester-Hagan provision should be based on sales of food that is subject to FSMA, whether the produce standards or the preventive controls rule. Sales of food that would not be regulated under FSMA should not be included.

The FDA should not rush the process of revoking a producer’s Tester-Hagan exemption. The agency has other mechanisms it can use if there is an immediate threat of foodborne illness.
a) The FDA should be held to specific evidentiary standards before it can revoke a farmer’s or food facility’s Tester-Hagan exemption.
b) A farm or facility that is exempt under Tester-Hagan should be given at least 90 days to submit evidence and defend its exemption if FDA seeks to revoke it.
c) If the exemption is revoked, the farm or facility should have at least two years to come into compliance with the FSMA rules.

On-farm Produce Standards Rule:
The FDA’s approach to traditional farming methods, such as diversified livestock-crop farms, the use of working animals, and the use of biological soil amendments, is fundamentally flawed. The agency should not restrict these sustainable methods of farming without data showing an actual, verified increased rate of foodborne illness; the simple fact that these methods include diverse microbiological communities is not a sound scientific basis for restricting them.

The waiting period between applying manure and harvesting the crop should be no more than 4 months, and there should be no waiting period between applying compost and harvesting the crop. The excellent track record for safety on organic farms shows that this standard is sufficient.

Compost teas and other biological inoculants, including normal additives such as molasses, should be treated the same as compost.

Water testing should not be required more often than once a month, and farmers should be able to test less frequently after establishing the safety of their water source through consecutive negative tests. In addition, farmers should be given the option to test for pathogens, rather than having to treat or stop using the water that tested positive for generic e. coli.

The provisions on wildlife and domestic livestock need to be clarified to protect farmers who use biologically diverse farming from field inspectors using their discretion to require measures such as fencing or destruction of habitat.

Preventive Controls and HARPC Rule:
“Very small facilities” should be defined as being under $1 million in total annual sales, adjusted for inflation. Imposing HARPC requirements on businesses smaller than that is unnecessary and overly burdensome.

Any requirement for “supplier verification” should not prevent a facility from purchasing foods or ingredients from farms and facilities that are exempt from the regulations under the Tester-Hagan provision or other exemptions.

Low-risk activities conducted by a farm using its own products, such as making jams, grinding grains, or dehydrating vegetables, should not be subject to these regulations.

Low-risk activities, when conducted off-farm or by multiple farms working together, should not be subject to the same requirements as high-risk processing activities. The requirements should address both the scale of the operations and the level of risk of the activity.

How to Eat for Free (Occasionally)

It pays to go to farmer’s markets and to get to know the farmers! Yesterday, I scored free hamburgers (and really good hamburgers at that) and a ton of slightly bruised tomatoes. Between that and zucchini that I grew myself, my dinner tonight was practically free!

Thanks to Kim at Black Bottom Farm for the free burgers — they *are* really good. Kim was kind enough to offer me the burgers after I also procured some of her bulk ground beef and breakfast sausage patties — those are a breakfast staple for me now. I ended up grilling the burger patties this evening. They are perfect!

When I mentioned to another farmer that I was planning on freezing tomatoes for use later, she offered me a bunch of her slightly bruised produce to go along with my purchase. Those bruises won’t matter when I process the tomatoes into sauce later. Score!

This isn’t the first time I’ve gotten food for free simply by chatting with one of the vendors about my plans for their food. It helps to be working with an item that is in over-abundance (like tomatoes right now).

I didn’t have to ask for these freebies, but I have invested time to talk with each of these farmers in the past. I even visited Black Bottom Farm not too long ago (read my post about the farm here).

Go ahead and give it a try. You’ve got nothing to lose by learning more about the food you eat by talking with the people who grow it for you!

Garden Update

I think I’ve harvested the last of my zucchini. There are still blossoms on my lone zucchini plant, but the bulk of the plant is looking pretty rough. My cucumber plant still has tons of blossoms on it though, so I hope it will keep producing.

A critter now truly has been after my baby pie pumpkin plant, so I found a recipe for rabbit repellant made from cayenne pepper, hot sauce, water and dish soap (just a little) and I sprayed that on the plants today, including on the sole little pumpkin that is nestled between two marigolds (the only reason it’s still around, I think). I have two huge gooseneck pumpkins growing by my garage.

My tomato plants also don’t look that great but are still bearing fruit. I need to cut back some other straggly plants that are past their prime and think about seeds to plant for the fall. I want to plant peas, more lettuce and kale. I’m thinking of transplanting the rosemary out of my VegTrug so that I can completely refresh the soil in that before doing anymore plants in it. The kale in there is looking anemic. I might wait for the basil growing in that container to die off first though…

I’m also already dreaming about what to plant next spring. I want to add at least one raised bed to my yard — I’m thinking lots more beans, some melons and plenty more squash plants.

This Little Pig Went to… the Pig Farm!

It was a hot, sunny day for my little pig to be out on the farm, but she had a good time.

It was a hot, sunny day for my little pig to be out on the farm, but she had a good time.

Maggie and I visited Black Bottom Farm in Galena, Md., today! They actually have a lot more than pigs — cattle, turkey, chickens, rabbits and veggies too. They’re launching a CSA this summer. You can find out more on their Facebook page. The farm is open to visitors on Saturday afternoons.

I chat with owner Kim Wagner at the Easton farmer’s market (she’s there every other week, trading weekends with SB Farms — the bison folks). I mentioned that I’d been down to visit Polyface Farms a few years ago and I thought their pigs must be the happiest on earth. Kim said she challenged that. After all, her pigs are pastured and have the run of the woods for plenty of shade (just like at Polyface), AND they are fed cheese wheels from Chapel Country Creamery, gourmet bread and sprouted oats. I got a tour from Kim and her kids today. She was kind enough to send me home with some of the hummus that will be offered through the CSA. I picked pineapple pesto from the flavors available. Enjoy the photos of their farm below!

A pond on the property.

A pond on the property.

Maggie getting up close to one of the rabbits.

Maggie getting up close to one of the rabbits.

Mama pig.

Mama pig.

The runt of the litter emerging from the woods.

The runt of the litter emerging from the woods.

Piglet's-eye view.

Piglet’s-eye view.

Maggie kept her distance from the piggies most of the time -- she was vastly outnumbered.

Maggie kept her distance from the piggies most of the time — she was vastly outnumbered.

Kim said, “If you leave here thinking that you wouldn’t mind being a pig on this farm, we’re doing it right.” That she is! The pigs were social, obviously well-fed, and there wasn’t any smell. If you get the chance to visit Black Bottom Farm, do it! Or at least buy their meat. I picked up Santa Fe-seasoned sausage at the market this morning and can’t wait to have it for breakfast this week.

The Haul: Field Trip Edition

bison2I used up the rest of my bison meat a couple of weeks ago, so I ventured out to SB Farms in Hurlock today to pick up some more. I bought ground bison, a chuck roast and some jerky–enough to get me through until the open-air Easton Farmer’s Market reopens on April 13. Farmer Bill Edwards was kind enought to give me a little booklet with recipes, including one for bison bbq, which I intend to make out of the chuck roast. I took some photos while I was out there:

jiggs

The resident greeter at the farm.

eagles

Two bald eagles have a nest on the farm as well.

bison

In other haul news, Eating Out of the Box has started up again in Easton and they now offer a la carte options! This week, I ordered baby carrots and two kinds of breakfast sausage. I supplemented this with kale, lettuce and salad turnips that I bought earlier this morning from Provident Organic Farm’s stand in front of Rise Up Coffee.

The Haul: Yes-Even-in-February Edition

2013-02-22 22.17.20

That’s right, all through winter, I’ve been able to get fresh, local produce thanks to a couple local farms and a CSA. This morning, I went to a small farmer’s market that’s open every Saturday morning starting at 10 in front of Rise Up Coffee here in Easton. I stocked up on a lot of greens as that’s what’s available this time of year. I’m on a mission to get back to my pre-holidays self and so I’m back to basically eating meat, veggies and a little bit of fruit. I have a huge pile of greens with almost every meal.

This week, I bought:

  • Chard (I really wanted spinach, but this was the next closest thing)
  • 2 kinds of lettuce
  • Kale
  • Carrots
  • Sweet Potatoes

In the upper-right corner, you may have spied the topic of my next blog post. I didn’t get it at the farmer’s market this morning — those aren’t grown locally, of course.

The Haul: Christmas Clam Edition

DSCN4181Yesterday, I returned to the Easton open-air farmer’s market for the first time in a few weeks. It’s smaller now, but it was still hopping. Here’s what I bought:

  • Maple sausage
  • Sweet onion
  • Garlic
  • Fuji apples
  • Chamomile tea
  • Christmas wreath

Then I stopped by the seafood market and picked up a dozen littleneck clams, a pound of wild salmon and a lemon. I found this recipe for steamed mussels and clams. I didn’t have a lot of the ingredients (including the mussels), so I made a lot of substitutions.  I had to make my own cocktail sauce, but didn’t have horseradish, so I added hot chinese mustard. The sauce ended up pretty ketchup-y, but was still good. I don’t usually have butter in the house, so olive oil stood in for that in the other sauce. The dish was really pretty and tasted pretty good too. The juxtaposition of the red and green sauces is perfect for this time of year.

 

DSCN4179

There is a new type of farmshare in town that is really neat. Eating Out of the Box has both medium and large boxes on offer and they gather produce from various farms in the area. I get mine delivered. The boxes become available in the middle of the week, which is nice because that’s about the time I run out of fresh stuff from the weekend market. I’ve tried it twice and gotten some really good stuff including lemongrass, Asian pears and all kinds of greens. This week, joi choi arrived (a larger version of bok choi).

The thing I love about farmshares is that you get ingredients you wouldn’t normally buy and so you learn to cook new dishes. I’m still trying to find something to do with the huge daikon radish that arrived this week.

Falling Behind

This week’s haul.

I have been making it to the markets lately I just haven’t been managing to blog about it. I did score quite a bit yesterday.

I bought:

  • 2 eggplants
  • 2 half-pints (okay, so 1 pint) raspberries
  • 2 pints cherry tomatoes
  • 1 jar of dark local honey
  • 1 spaghetti squash
  • 1 butternut squash
  • 1 bunch kale
  • 1 pound hot Italian sausage
  • 1 pound ground beef
  • 1 half-pint Chapel White (marinated feta from Chapel Country Creamery)
  • 1 mini pumpkin-like gourd (to accompany a mini goose-neck gourd I bought last week)

THEN, I went to the Renaissance Festival with friends and bought still more honey (blackberry), plus honey soap, and a large pottery mug from which to enjoy cider and beer while walking around (I also stuffed my face with ocean-style fries, sweet potato fries and steak on a stake).

Today for breakfast, I tried to make Bob’s Red Mill gluten-free pancakes, but I had to substitute applesauce for the egg called for on the packaging. I’m guessing this is why the finished pancakes still had the taste of raw batter even though they seemed to be cooked through. Phooey. I will keep experimenting.

I also made homemade pork sausage with ground pork from a new-to-me vendor — Country Vittles from Critter Hill Farm out of Taneytown, Md. They are at the UMD farmer’s market on Wednesday. I’d already eaten their beef jerky and beef kielbasa earlier in the week. The pork made for good sausage, but I think that my favorite is still that from Black Bottom Farm. I’ll definitely be getting more jerky from Critter Hill in the future though. Kudos to them for making it without nitrates/nitrites.

For lunch, I made homemade sweet potato oven fries, a Chapel White burger (using beef from Black Bottom Farm) and reheated roasted kale from earlier in the week.

Dinner was super-yummy. I made this recipe for “pasta” with sausage, eggplant and feta. I used roasted spaghetti squash instead of the penne called for in the original recipe. I substituted spicy Italian sausage for the breakfast sausage, chopped fresh tomatoes for the canned and added crushed red pepper for still more heat. The marinated feta was really good in this.

Garden Update — Very Naughty Caterpillar Edition

The seedlings and plantlings I have started in the VegTrug haven’t been growing as fast as I’d like to see, so I resolved to finally “harvest” some of my compost to see if that will help them along. Finally, after a year and a half of faithfully saving all of my vegetable/fruit scraps, shredded docs, toilet paper tubes and similar, I gathered a bucketful of “black gold” and headed over to the VegTrug.

Before I could distribute this homemade fertilizer amongst the new plants though, I had to evict some caterpillars who had taken up residence on my most mature carrot, stripping it of all its leaves. I went ahead and harvested it. It appears some of the younger carrots had suffered damage too, but they didn’t have enough greenery to interest the caterpillars for long.

Here’s hoping that’s the last I see of them and that the remaining carrots, kale, spinach and broccoli seedlings and plantlings enjoy the compost.

Allergy Update — Going Nuts Edition

Either I am quite in denial that some food I have re-introduced back into my diet is causing me problems or something I never stopped eating is the culprit behind some skin problems I’m still confronting. My thought is that it’s the latter, as I never truly kicked all of my issues when I started this process back in June.

My next strategy is to cut out tree nuts for at least a week and then see if that makes any difference. Then, reintroduce them and see what effect that has.

I’m already allergic to pecans and walnuts. Lately, I’ve been relying on almonds and cashews as snacks to round out my diet as I need more protein than I used to. My thought is that since I’m already allergic to some tree nuts, other tree nuts are likely to be a problem as well.

I’m also considering that the soaps I use, even though they are already dye-free and unfragranced, may still be an issue. If the nut omission from my diet doesn’t have any effect, I think I’m going to try going even more basic on my soaps and detergents before I omit anything else from my diet.