good ag gone bad
By Andrew Rodman and Garth Kahl
Triple-washed, processed salad greens are supposed to be good for you, not make you seriously ill. Yet in 2006, a tragic outbreak of E. coli 0157:H7 was linked to processed, bagged salad. This was a disaster for the greens industry, with five dead, and 204 sickened and more suffering kidney failure. The war on germs in the field kicked into overdrive. The outbreak of 2006 was the 20th outbreak associated with leafy greens from the Salinas Valley since 1995.
In a response to this crisis, the major players in California’s leafy greens industry strengthened rules to avoid future contamination, and win back consumer confidence. On June 29, 2007, the California Leafy Green Products Marketing Agreement (LGMA) unanimously approved a start date for mandatory compliance audits of its members. Its scope includes all leafy greens grown in California. In October 2007, The Commodity Specific Food Safety Guidelines for the Production and Harvest of Lettuce and Leafy Greens document was finalized. This document was intended to supplement, already established food safety program components such as Good Agricultural Practices (GAPs).
In October 1998, the FDA issued its Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables. The Guide’s intro states that GAPs provide general food safety guidance on production steps where food safety might be compromised during the growing, harvesting, transportation, cooling, packing and storage of fresh produce. GAP guidance alerts growers, shippers, packers and processors to the potential microbiological hazards associated with aspects of the production including: land history, adjacent land use, water quality, worker hygiene, pesticide and fertilizer use, equipment sanitation and product transportation.
The Guide identifies potential sources of contamination including high concentrations of wildlife in the growing and harvesting environment (such as nesting birds in a packing shed or heavy concentrations of migratory birds, bats, or deer in fields).
The vast majority of the lettuce/leafy greens industry has adopted GAPs as part of normal production operations, and undergo internal or third-party GAP audits regularly.
Will Daniels, VP of Quality, Food Safety and Organic Integrity at Earthbound Farm / Natural Selection Foods wrote in the 2007 fall edition of Certified Organic “it is important for every part of the food chain to do its part to protect the consumer: large or small, local or global, farmer or processor.”
A rival set of food safety standards to GAPs developed by the Food Safety Leadership Council has been lambasted by Western Growers’ President Thomas A. Nassif as “excessive and scientifically indefensible.” The council includes representatives from such retail giants and food-service providers as McDonald’s Corp., Wal-Mart Stores, Inc., Publix Super Markets and the Walt Disney World Co. In a letter to Publix, Nassif warned that the council’s standard “marks the beginning of a destructive food safety ‘arms race,’” with different produce buyers competing by claiming they have safer products than the next, and imposing ever more stringent standards on growers. These so-called “super metrics” are at the heart of the controversy for growers and conservationists.
Conservation agencies and environmental groups say that GAPs and super metrics are triggering changes that are eroding hard-won gains in protecting wildlife and its habitat. Farmers are reporting increasing pressure to remove everything that might attract wildlife to fields of leafy greens, and many other crops. Practices being promoted include the destructive treatment of vegetative buffers and hedgerows, which are seen as harboring disease-infested wildlife. The Wild Farm Alliance (WFA) has been documenting the adverse effects of “safety” measures in the Salinas Valley, including overzealous bulldozing of hedgerows and fencing off waterways.
A major tenant of organic and biological farming is esablishing buffers and hedgerows to attract pollinators and provide habitat for beneficial insects.
Christina Fisher with the Nature Conservancy says Fresh Express has even told farmers it doesn’t want to see any frogs in their fields. With such intense market pressure and competition, farmers have little choice but to do whatever their buyers require. Judith Redmond, a co-owner of the certified-organic Full Belly Farm near Sacramento, told Science News that the greens’ guidelines threaten to put farming at odds with environmental goals. For the past two decades, she says, “a vanguard of farmers has been trying to figure out how to farm with nature [and] be good environmental stewards.” San Joaquin Valley organic farmer Tom Willey is an outspoken critic of the Leafy Greens Agreement and sterilization for safety. “You want to farm in an environment that is overwhelmingly occupied by microbial allies rather than zero microbial relationships.”
Trouble down south
For over 23 years, Larry Jacobs and Sandra Belin, of the Pescadero, California-based Jacobs Farm/Del Cabo, have worked with small growers and cooperatives in Mexico to produce and market exceptional quality herbs and tomatoes with a model that promotes genuine economic stability and health in the rural communities and cooperatives they work with. GAPs are taking a huge economic bite out of operations like Del Cabo and other small farms, threatening to put this model of economic development firmly out of reach of most small growers in Mexico.
On organic farms all over Mexico, fields are being fenced by four feet of black plastic, the ostensible purpose of which is to keep out rabbits and other small animals. Of course these rapidly degrade in the intense heat and UV light, becoming another waste disposal problem in a country where recycling is still in its infancy. Where whole families once worked together to cultivate their land, and babies and toddlers sat in the shade of hedgerow trees while their parents worked, fields supplying Del Cabo are now required to sport signs prohibiting the “entry of children” into the fields. Complained one Del Cabo manager, “I can’t even wear shorts to work because of the GAPs, and it’s 100° or higher in the shade here!”
Explained Larry Jacobs, “we’ve had to take the horse off the label because animals aren’t allowed in the field anymore.” The single horse-drawn cultivator, still widely used in Mexico, is one of the most efficient and sustainable cultivation techniques, especially for cultivating between long rows of tomatoes. While Jacobs Farms is complying with GAPs, investing literally millions of dollars in packing facilities, the regulations put a huge strain on the company and their associated growers. “If the regulations had been like this when we started,” Larry continued, “there’s no way we would have ever been able to do it.” The regulation now mandates porta-potties, which cost growers nearly a thousand dollars each, where soap and a bucket of clean water once sufficed. Plastic crates and mobile carts are now required to prop up field cartons during harvest, because boxes cannot touch the ground during field packing. Juan Alberto Agierre, an agronomist in charge of Del Cabo’s operations in southern Baja laments, “we used to bring buyers down here on field trips so they could see what a good job we’re doing. Now we just talk to sales people and all they want to know about is our GAPs.” This loss of personal ties between the grower and consumer is fueling the movement to GAPs. In the absence of people knowing or seeing how their food is grown, they are increasingly relying on governments and standards to provide them with a feeling of security, rather than taking the time to know their growers, or at least the wholesalers who buy from their growers, and taking some personal responsibility, like washing their food.
Though GAPs mostly impact conventional operations, the obsession with food safety has historically affected organics. The National Organic Program (NOP) rule, with its restrictions on and definition of compost, together with the long “pre-harvest interval” between the “application” of raw manure and harvest, have curtailed or eliminated such sustainable practices as biodynamic-style compost or the grazing of orchard floors. As former Tilth Executive Director Yvonne Frost put it years ago, upon seeing the draft of the NOP regulation pertaining to compost and manure, “I’m afraid we may have gotten more than we asked for.” While not noted in the preamble to “The Rule,” many believe that the USDA’s restrictions on compost and manure use were a bone thrown to Alex Avery and his organization, Center for Global Food Issues. For nearly 15 years, Avery has been the chemical industry’s point man against organic farming and repeatedly raised food safety concerns about the use of manure on organic farms.
Common sense in short supply
Vegetation planted in waterways and alongside fields not only reduces pathogens like E. coli but also promotes the uptake and degradation of fertilizers and pesticides, explains Jill Wilson, environmental scientist at the Central Coast Regional Water Quality Control Board. “We want to see water quality programs and food safety practices coexist,” she says. Meanwhile, WFA states in its paper Food Safety Requires a Healthy Environment – Policy Recommendation for E. coli 0157 that “We could build upon conservation practices, already underway on many farms, to enhance the effective ecosystem services provided by a healthy growing environment while ensuring the safe growing of food.” WFA’s paper concludes, “A healthy growing environment will enhance both food safety and the ecological role of farms in our landscape.” Neither GAPS or super metrics have much to say about concentrated feed-lot operations, a serious spawning ground for virulent strains of E. coli that wildlife can be the vector of. Instead, there is finger-pointing at wildlife. Even slugs are implicated as vectors of E. coli.
When nature and common sense are seen as the enemy of farming, where does it end? Tom Willey shakes his head and says, “even if it could be done, agriculture wouldn’t function in a situation like that. Is this some kind of freaking laboratory business? You’re working with biology.”