Good Agricultural Practices (GAP) Gone Bad



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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.

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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.

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View Comments (9)

  1. Thursday, April 23rd, 2009
    Small farms, caring farmers, knowledgable, well informed consumers are the future.

    If more rules and regulations are spun from clouds by lobbyist, large corporations, and those supposedly in power to protect us from the very health concerns they say might harm us, we will forever be in danger of eating poison.

    Shop smart.
    Eat local.
  2. Thursday, April 23rd, 2009
    As a farmer and an eater, I believe very strongly in regulation. I just believe in good regulation.

    Despite the poorly written and ill-conceived regulation that are coming out at the (usually) federal level, there are some bright spots in food safety. On example with which I'm familiar is the Washington State Department of Agriculture who, from the ground up, are coming up with some very sane regulations that both ensure safety more effectively (in my opinion) and are more small-farm-friendly than the cumbersome and prescriptive regulations that we love to complain about.

    For example, at a Tilth Producers conference a couple of years ago I attended a session on small dairy certification hosted by a farmer and a representative of the WSDA. The farmer indicated that one of the challenges of certification in Washington is that the regulations specify *results*, not methods. It's left to the farmer to figure out how to meet sanitation goals, not how to pay for the specified equipment. As an eater, I don't care how far the domestic animals are from my greens, I care that the result of the handling is food free of contamination. A small farmer can spare the attention to detail to manage handling as intensively as a small farmer must manage production.

    An example of WSDA's sane approach to regulation is that, when a farmer found the requirement for a commercial dishwasher too onerous, he was able to demonstrate to the local inspector that a consumer model dishwasher offered the same results as the commercial dishwasher at a fraction of the cost. Thus, the inspector was (rightly) satisfied, the farmer was able to produce dairy at the appropriate scale, and the consumer was assured of a clean and wholesome product thanks to the active, critical, and results-oriented involvement of the agency as well as the diligence of the farmer in researching the problem instead of being forced to focus on regulations.
  3. Thursday, April 23rd, 2009
    I want the government OUT of sweeping food and farming regulations. These bills that are coming down the pike are downright scary! Monsanto-backed legislation is NEVER going to be in the best interests of the consumer. I believe in local sustainability and small local economies. Unfortunately, our government is on a Globalization trek. Thank you for a window into CRAFT farms.
  4. Thursday, April 23rd, 2009
    Here's the thing: There's never anything black and white. It's not a large farm vs. small farm issue; it's a good manager vs. poor manager issue.

    I've been on small farms that are poorly managed that you could not pay me to eat anything from, and I've been on large farms that are well managed and I would gladly eat or drink anything raised on that farm. So it disturbs me to read that small farms should be protected or exempted from farm and food safety regulations (which I wholeheartedly agree are usually unreasonable) simply because of their size.

    It's like the horse owner who thinks manure from a single horse doesn't have the capacity to pollute like manure from a 50-cow dairy (dairies manage their manure much more soundly than most horse farms).

    I certainly hear and understand and agree somewhat with what you're saying: Every regulation will have unintended consequences. But it's all about management, not size.
  5. Andrew
    Thursday, April 23rd, 2009
    what about exemptions for farms that sell directly to their customers? when hundreds or even thousands of eaters personally inspect how their food is grown, they don't need the government to tell them that it's safe.
  6. Saturday, April 25th, 2009
    An excellent, informative, and somewhat depressing analysis of our regulatory system and its impact, intended or otherwise, on small farms.

    I know this is stating the obvious, but we need to formally declare the existence of at least two viable food systems. Perhaps current regulations will remain appropriate for industrial agriculture, but they would be rewritten or abandoned for small, sustainable (and/or organic) farms.

    Is such a system realistic? I hope so.
  7. Monday, April 27th, 2009
    What a great perspective on the relationship between regulation and the small farm... I've just started my first foray into farming and am learning so much about the battles that my mentors have had to fight to bring food to their consumers -- hosting a farm store that includes other farms' products, small scale chicken processing...

    The place where I am now serves a very small local population -- CSA, farm stand, farmers' market and one restaurant. I can only imagine how much more complicated it gets when you start scaling up and dealing with new kinds of distribution.
  8. CHANGOO JO
    Monday, May 4th, 2009
    Dear sir

    We are a group of students from South Korea and funded by one of major companies, LG. This program financially supports students who are willing to find our insightful ideas from other countries.

    We choose our topic as ‘To find a way to boost unsystematic Korean GAP (Good Agricultural Practices) from the improved GAP in the United States‘. In South Korea, we don’t really have the systematic the GAP system. In this regard, we find a great example from the GAP in the United States that is keeping up with various demands of people.

    However, it is hard to find way kind of information regarding the improved GAP system on the internet. Therefore, could you let us know if it is available for us to visit your center? We are going to leave for the United States in July or August, 2009. We are 4 people (2 male, 2 female).

    Unfortunately, if it is not available to allow us to visit you, could you recommend people who have knowledge related to the topic?

    We are looking forward to hearing you as soon as possible.

    Best wishes

    CHANGOO JO from Gyeongsang National University in South Korea