FarmsReach and ALL distributors of food that store any food are “facilities” under the 2002 Bioterrorism Act and must be registered with the FDA as required by 21USC350d. Under Sec. 103 of the proposed S 510, these food distributors (like all food facilities) will be required to develop and implement “Hazard Analysis & Risk-based Preventive Controls” covering all of the food they distribute. Under Sec. 104 Performance Standards, they will also be required to meet whatever additional standards are set up by the FDA. In addition, the existing traceability requirements will be increased.

In my 14+ years working to revive local, healthy food (a simple a web search will clearly demonstrate who I am), I have never heard of any distributor that has even one of these HACCP-styled plans. I have never heard of such a plan having been written. As the owner of a small food distributorship in conjunction with a retail store who has worked full-time since July 2009 learning about these plans and other proposed “food safety” requirements, I have no question that our distributorship will not be to survive as a stand alone when the new regulations come into force. Furthermore, I have seen no evidence that there is any reason to believe that HACCP-style plans will improve the overall safety of food distribution in the US. In fact, because the regs will be more expensive and difficult for sustainable ag to implement than industrial ag, S 510/HR 2749 will further tighten industrial ag’s control of our food system.

Ironically, Dr. William Sperber, one of developers of HACCP and the “Global Food Safety Ambassador” for Cargill pointed this out back in 2003 in his paper, “HACCP does not work from farm to table.”

For more info or to help, please write me at healthyfoodcoalition@gmail.com.