National Leafy Greens Marketing Agreement
The proposed NLGMA would be detrimental for organic growers and the environment if passed. Oregon Tilth was at the recent hearings in Monterey, CA to give testimony in opposition.
One of our own here at Oregon Tilth
attended the recent hearings for the proposed National Leafy Greens Marketing
Agreement in Monterey, California. Working in concert with a number of
other conservation and organic farming groups including the Wild Farm
Alliance, Community Alliance with Family Farms, and the National
Organic Coalition, OTCO presented testimony in opposition of the Act,
which OTCO believes would have serious detrimental consequences for
organic growers and the environment, while little to decrease the
incidence of food-borne illness.
Here are the issues:
1) There is a great deal of concern that many of the measures promoted by the LGMA will penalize farms that promote wildlife habitat and natural pest and pathogen control through conservation practices, such as vegetated buffer and filter strips. Several growers based in California have already voiced concerns about the effects of the California Leafy Greens Agreement, which has led to the clearing of hedgerows, riparian buffer areas and the construction of fences that are an impediment to wildlife. We assert that these measures are based on assumptions about the pathogen risk from deer and other wildlife that preliminary data suggest are completely misplaced. According to a recent California Dept. of Fish and Game report, recent research results from a joint CDF&G/USDA study suggest that suggest less than one half of one percent of mammalian wildlife tested positive for E. coli O157:H7. This would suggest that the removal of wild riparian and insectary habitat might at best be unnecessary and at worst counter productive. There is nothing in the LGMA that suggests that the proliferation of the so-called “super metrics,” responsible for some of the worst abuses observed under the California LGMA, would cease or decrease.
2) There also lies concern about the high costs to small and medium sized growers in complying with metrics mandated by the LGMA, and the seeming “one size fits all” approach to food safety inherent in this agreement, particularly the costs of updated handling facilities, maintenance of HACCP programs, etc. According to a recent UC Small Farm Program Research Brief, additional costs to growers for compliance with the California LGMA are estimated at $100/acre with the highest costs being borne by small and mid-sized growers. In Mexico many small growers report having to assume considerable debt or even switch crop types to comply with other recently-enacted marketing agreements or buyer-mandated food safety programs, particularly the California LGMA. In addition, many growers report what some have termed “audit fatigue,” for the proliferation of audits mandated handlers, private food safety entities and organic inspection.
3) Oregon Tilth and our members are concerned that, far from being a voluntary agreement, the LGMA will in fact become mandatory for at least the majority of medium to large-sized leafy green growers in the country. If 50 percent or more (by volume) of the leafy greens handlers sign-up for the Agreement, it will be very difficult for other handlers to decline to sign the Agreement. The N LGMA standard will essentially become the governing baseline standard for handlers and producers selling to them.
Oregon Tilth believes that marketing agreements are a bad way to implement food safety and that food safety regulations, where necessary, should be developed in an open, public and transparent process with the lead role going to a food safety agency such as FDA in close coordination with USDA. We further believe that any food safety regulation must be developed in close coordination with the National Organic Program, to ensure that regulations do not result in unintended conflict with the organic standards. In addition standards should not ignore the benefits inherent under the existing NOP program, such as such the strict the requirements for the documented composting of manure.
We further believe that Regulation should take the scale of operations in to account and target the areas of greatest risk, and that the assessment of those risks should be scientifically based. Part of the analysis of risk should also be recognition that scale of operation plays a role in determining risk.
Upcoming NLGMA Hearings:
The hearings provide the public an opportunity to learn more about the proposed agreement and to offer comments in support of or opposition to the agreement. The hearings will be held at the following locations from 8:30 a.m. to 5 p.m. (local time) or as determined by the presiding administrative law judge: