After a hot, sweaty introductory year of organic farming in Georgia, I decided to devote a second year to working as an apprentice farmer in Massachusetts.  Cooler weather was not my only reason for the migration; I wanted to be a CRAFT apprentice.  CRAFT (the Cooperative Regional Alliance for Farmer Training) is a loosely affiliated network of small sustainable farms , all of whom take on apprentices and send these young greenhorns on bi-weekly visits to other CRAFT farms for lectures, tours, and farmer networking.   Several CRAFT farmers were among the first sustainable growers in the country; Community Supported Agriculture was born here.  It is a fine place to be a student of farming.

Last weekend, we had our first CRAFT visit, to a farm I will not name specifically, out of respect for the farmers’ privacy.  Amidst a potluck of epic proportions and copious introductions we found time to tour the farm and ask all of our nerdy farmer questions about soil, horsepower, and sales.  This farm, though still very much a small family operation, has moved over the years towards greater specialization and scale in their veggies. Salad greens are a particular forte of theirs, as greens are well suited to the cool climate and are always in demand with local chefs.  When their daily harvests (of salad greens, mind you) began totally several hundred pounds, they recently invested in a stainless steel washing system with tanks and hoses and a little conveyor belt.  Tipping the scales at $30,000, this system was a big investment for them.

The washing station catalyzed a Q&A amongst apprentices and farmers that revealed a side of the current food safety debate that many Americans do not recognize or understand, and which, especially at this juncture, is of critical importance to the small organic producers that I work for and strive to someday become.

In short, the issue is largely a matter of scale.

You see, this fancy, efficient, very expensive washing station is now somewhat worrisome to our farmer, on account of a USDA certification program called GAP (Good Agricultural Practices).   At present, GAP is voluntary, though many wholesale distributors, especially groceries, require it of their producers.  Our host worried aloud that with recent food safety scares, his restaurant clients might soon feel pressure from their insurance agencies to source only from GAP-certified farms.  He had attended a recent USDA presentation of GAP, and let’s just say that he was none too thrilled at the prospect of an audit.

This is not to say that his operation is in any way unclean—the fields looked immaculate; they are certified organic; he and his family are efficient, careful farmers.

The problem is not the farm, but the regulations, which are designed based on the recommendations from the USDA “Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables.” Participating farms must wade through a quagmire of steps-within-steps, drafting hazard plans and employee education programs, providing documentation that “crop production areas are monitored for the presence or signs of wild or domestic animals entering the land” and other such inane (and frankly unrealistic) rules are abided by.

The regulations prohibit domestic animals within 2 miles of any fruit or vegetable cultivation.  They strongly encourage approved “field sanitation facilities” with individual paper towels, hand sanitizer, and running water.  They take into account every conceivable risk (even that of the light bulbs on the tractor breaking and glass shards entering the spinach) and try to mitigate them.  All of that mitigation means several things.  One, it means that the farmer is spending inordinate amounts of time on a certification process rather than on his or her crops.  Two, it means that an independent certification agency is being paid (by the farmer) for 10-20 hours worth of work to double-check compliance.  A score of 80% or more earns certification.   Three, it means that sustainable, clean farming practices (such as intentionally encouraging a woodland farm border, for the beneficial animals and insects which this facilitates, or washing your lettuce with well water, rather than a hyper-chlorinated brew) are discouraged, because they do not fit the big ag model.

It does not necessarily mean your food is any safer.  Risk, by definition, is not something that can ever be fully eliminated.

Our host looked at his shiny new washing system and shook his head.  “Within two loads of greens, the water in there is contaminated,” he said ruefully.  I assumed I had misunderstood and raised my hand.  “And by contaminated, do you mean with dirt?” I asked.  He laughed yes, and we all shook our heads.  His options to clean the wash water?  He could add a certified organic washing additive to the water, hyper-chlorinate it, or possibly look into UV light purification.

This is not the future of food that I had envisioned for myself.

The problem with GAP, the problem with more pressing legislation like H.R. 875 and H.R. 759, is that they do not differentiate between our CRAFT farms and big agribusiness farms (or even industrial organic growers like Earthbound Farms).  When you move 5000 pounds of spinach in a day, maybe you do need bathrooms in your mammoth fields.  When your neighbor is a CAFO pig operation with an utterly foul manure lagoon, maybe you should put some space between them and the escarole.  But at the level where I’m working, and at which I fervently believe a healthy, safe food system can be a reality, these are not the issues.

The issues are farmer access to land, facilitating direct sales (where farmers, rather than middlemen, make a profit),  allowing farmers to farm rather than do paperwork.  Vote with your pocketbook; vote with your stomach, just please vote with respect for small farms.