[Guest Post] FSMA: There’s Something Happening Here


Below is a pointed analysis of what is currently happening with the Food Safety Modernization Act written by Brian Snyder, Executive Director of the Pennsylvania Association for Sustainable Agriculture (PASA). He explains in apt detail that “what we’re really dealing with here is the potential culmination of a decades-long process of government policy being used to favor a fully industrialized food system…” The post originally appeared on Brian’s personal blog, Write to Farm.

To take action on FSMA, click here to submit a comment to the USDA by the Nov. 15 deadline. Stay tuned for more updates from RAFI in the coming days.

Brian Snyder, Executive Director of PASA

Brian Snyder, Executive Director of PASA


FSMA: There’s Something Happening Here

by Brian Synder

There’s something happening here
What it is ain’t exactly clear
There’s a man with a gun over there
Telling me I got to beware
I think it’s time we stop, children, what’s that sound?
Everybody look what’s going down
–Stephen Stills, For What It’s Worth, 1966

If you’re like me, you are starting to grow weary of all the hoopla generated by the Food Safety Modernization Act (FSMA) and the effort to generate public comments to the Food and Drug Administration (FDA) by the November 15 deadline. This has been a long slog, seeming perhaps like much ado about nothing to many who are not directly involved. Along with Stephen Stills, you might be tempted to agree that what’s happening ain’t exactly clear, and no one could blame you for that.

The tendency in situations like this is to exaggerate what’s happening, in order to get people to pay attention to what is otherwise a rather mundane subject. There has been plenty of that type of hyperbole in the food safety debate, and this writer is not totally innocent in that regard. But when the public discussion about food safety regulation began in earnest in early 2009 – following problems discovered with our beloved peanut butter – there were various public messages promising that backyard gardening was about to be outlawed by Congress. Well, such blatant falsehoods did more damage than good, directing attention away from some extremely important implications for our food system in the ongoing saga of passing and implementing FSMA.

It’s not easy to explain, but anyone experienced with monitoring food system policy knows that the most important aspects of FSMA have little to do with issues involving water, manure, exemptions or even definitions. What we’re really dealing with here is the potential culmination of a decades-long process of government policy being used to favor a fully industrialized food system over the preceding system, which was, unconsciously and by its very nature, more local, sustainable and organic in the way it functioned. Not an idealized golden age of any sort, and no one is advocating that we “go back” there, but what we had fifty years ago functioned much more in balance with the needs of our land and people, and better supported the common interests of rural and urban communities in particular.

But the years have taken their toll on our food, and our people and planet in the process. Those of us advocating for something better have sometimes been considered extremists, as we struggle to mesh traditional values and the indigenous knowledge of farmers with the advances of modern science that sometimes act like a sledgehammer on the landscape. Over the years, we “won” things like organic certification and country of origin labeling, but now seem to know less about the origin of food in the mass marketplace than we ever did. The tide of change has not been with us, and in many ways, FSMA represents the triumph of a tidal surge of food system policy that would make Superstorm Sandy seem like a routine romp in the kiddie pool.

Here’s why. It’s about authority, in two ways. First, there’s the further removal of decision making power away from farmers and consumers, and into the hands of government bureaucrats located more and more remotely from the production end of the system (don’t be fooled that this is a mere federalization of food production authority either). Second, FSMA potentially represents the final triumph of technology over nature in terms of which sector of our collective reality is calling the shots. You remember the “tree of wisdom” and “tree of knowledge of good and evil” from the Creation story in Genesis? In recent decades, the latter has been on a crusade with respect to defeating the former, and we are all the worse for it.

In other words, what we are now facing is not just the potential presence or absence of pathogens in our food, but the question of who will be responsible for our food in the future, how it will be grown, and under what authority. In more practical terms, the trend is almost certainly in the direction that will make it harder and harder – if not eventually impossible – to grow foods in less technologically intensive ways and bring them to local and regional markets without an industry-approved, profit-taking mechanism in the middle… which is roughly equivalent to the process that caused the vast majority of dairy farms in this country to fail.

The final determinations have not yet been made. FSMA comes at a time when public interest in knowing more about where and how our food is raised is greatly accelerating. With that trend, a plethora of new organizations and community-driven efforts aimed at encouraging healthier, locally grown food is also coming into prominence. Those of us within that “movement” do not always agree on priorities… in fact there has been a striking lack of interest among members of the so-called “foodie” crowd in terms of the relevance of the FSMA debate. But it is exciting to see the extent to which the sustainable agriculture community – more closely connected to farmers – is now driving the conversation, sitting for once at the head of the agricultural table instead of its foot.

There is no question whatsoever that we are, in this historic moment, witnessing a dramatic shift of leadership in terms of which organizations are speaking on behalf of rank-and-file farmers everywhere.
Industry experts and food safety activists are still shaking their heads in disbelief to behold what was accomplished in the legislative phase of FSMA by those who want to keep authority closer to the fundamental farmer-consumer relationship, thereby maintaining a proper balance of nature and technology in the system. Now those gains must not only be defended, but further advanced in the process of bringing FSMA regulations to fruition.

If you have not already weighed-in with written comments on the FSMA rules, you are in danger of forfeiting your opportunity to participate in history. Thousands of pages of necessary information have been boiled down and made available to you through an extraordinary effort by the National Sustainable Agriculture Coalition (NSAC) and their#fixFSMA campaign. Everything you need to know about the proposed regulations and how to comment can be found on the NSAC website, or even more succinctly on the PASA website (thanks to NSAC, of course). A petition cosponsored by NSAC and our very good friends at Farm Aid is included in both places. You can also consult numerous opinion pieces written by me and some of my friends and colleagues at the Write to Farm blog.

This flies against conventional wisdom, but I once witnessed a dramatic reversal in a massive drive to enact new dairy regulations here in Pennsylvania, spurred mostly by a beautiful poem written and submitted by a farmer, at just the right moment, to the authorities charged with the decision. If even a simple poem can change the world, then what is your excuse for not getting involved right now, and doing what you can?
I think it’s time we stop, children, what’s that sound? Everybody look what’s going down.

{This is my last blog post until after the November 15 deadline for submitting FSMA comments. Please help by distributing this piece, links to NSAC, and any other resources available to you as far and wide as possible, while there’s still time to act.}