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Food Safety

Overview of Food Safety and Organic
Food Safety Regulations

Legislative Update

CCOF Food Safety Press Releases
Food Irradiation

Overview of Food Safety and Organic

Conventional and organic food production and processing are covered by the same food safety regulations, under the jurisdiction of a number of governmental organizations at the federal and state levels, which include the Food and Drug Administration (FDA), the USDA, Health and Human Services, as well as state and local departments of Health. To read more about the connections between these agencies, see http://www.foodsafety.gov/.

New food safety legislation proposals and policy initiatives are often initiated as a response to an outbreak of a food borne illness or a public food safety problem. This was the case with the Leafy Greens Marketing Agreement (LGMA) in California. While increased regulation may well be required and advantageous, problems arise when a ‘one size fits’ all approach is adopted and when the implications of the new proposed legislation on all those involved in food production and processing are not fully considered.


For example, what is feasible in large scale agriculture production may not be workable for the smaller producer, and this is a particular concern for small-scale organic farmers. Similarly, food safety regulations that diminish biodiversity would be contradictory to the rules and philosophy that underpin organic farming. These topics are integral to the ongoing debate about California’s LGMA.


There are also occasions when new food safety regulations contradict or conflict with the regulations of the USDA National Organic Program (NOP), that determines what is allowed and not allowed in the production of certified organic food. Food irradiation is a good example of how a food safety solution applicable for conventional agriculture may not be allowed for certified organic agriculture.


To encourage the dialogue and exchange of ideas on this topic, CCOF hosted a two-day Food Safety Conference in January 2008 at Asilomar Conference Center, Pacific Grove. Read more.


CCOF regularly monitors food safety research, laws and regulations on behalf of our members, consumers of organic food and the general public who wish to protect organic farming. If you wish to keep up-to-date with issues in organic, we encourage you to subscribe to our e-newsletter and revisit our website regularly.

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Food Safety Regulations


CCOF monitors proposed food safety regulations, to tease out fact from fiction, to determine which pieces of legislation have merit and warrant our attention, and to decide which ones are just place holders and will be changed significantly during the legislative process.


New food safety legislation will most definitely be passed. As any food safety bill gains momentum and credibility, CCOF will use our lobbying expertise and leverage and work closely with our colleague organizations to make sure our collective voices are heard on this crucial subject. The real battle occurs in the rule-making process that follows the passage of any bill. CCOF will be working to ensure any legislative changes do not harm or competitively disadvantage organic farmers.


We also encourage members with concerns about any legislation to call your Congressional representative and let them know that you’re aware of the issue and are watching how Congress handles this crucial situation.


Listed below is a legislative update.

Legislative Update

H.R 2749 - Food Safety Enhancement Act of 2009

(Update 7/15/09) CCOF sent a etter to members of the House Committee on Agriculture expressing concerns onH.R 2749. Read letter.

 

Presidents Food Safety Working Group

(Update 5/15/09) The President has created a Food Safety Working Group. CCOF will be submitting comments to this working group.

Leafy Greens Marketing Agreement

CCOF remains involved in monitoring the impact of the Leafy Greens Marketing Agreement (LGMA), which formed in the spring of 2007 as a response to an E-Coli related food borne illness outbreak in September 2006 that was mistakenly linked to organic farming practices.

At the time of the above outbreak, CCOF issued press releases to defend organic agriculture against attacks and layout the facts. In addition, CCOF dedicated a two-part series on the topic of food safety to the main feature articles of the Fall 2007 and Winter 2008 editions of CCOF’s quarterly “Certified Organic” magazine. The articles were entitled ‘Food Safety: Uncovering the Facts and Myths Surrounding the E.coli Outbreak of 2006’ and ‘Bridging the Leafy Green Divide. Read archives of past magazines.


The LGMA is a voluntary program; however, all mainstream retailers are now requiring enrollment in it. Operating with oversight from the California Department of Food and Agriculture (CDFA), the LGMA verifies that farmers follow accepted food safety practices for lettuce, spinach and other leafy greens through mandatory government audits. The LGMA adopted Good Agricultural Practices (GAPs) for leafy greens, which serve as the cornerstone to the LGMA. The strengthened GAPs have been presented to California growers and handlers, and CCOF representatives continue to stay involved on this topic to ensure our members, especially small growers, are not left out of the discussion. Claudia Reid, Policy Director for CCOF, works with CCOF Board Chair Will Daniels, who currently sits on the LGMA Technical Advisory Committee, other organic farming representatives, and our partner organizations such as Organic Trade Association and the National Sustainable Agriculture Coalition to keep a close eye and ear on further developments with this issue. There are STILL no organic representatives on the Marketing Agreement Advisory Board at this time (despite CCOF's recommendation), so organic producers must remain vigilant on this topic.


Constructive discussion is beginning to occur between LGMA, retailers, federal and state agencies concerned with habitat, water and air quality issues and farmers, but according to one retail representative, “it will take a long time” to build back a level of trust between retailers and farmers because of the deaths and disease resulting from the E Coli outbreak.
Visit the CDFA website to read more.

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CCOF Press Releases on Food Safety

CCOF Press Release: No Evidence to Link Organic Spinach to E. coli O157:H7 Outbreak
The U.S. Food and Drug Administration and the State of California announced results from the field investigation of the outbreak of E. coli O157:H7, tracing a matching genetic fingerprint in spinach that sickened 199 people (and killed three) to samples of cattle feces and wild pigs found on a ranch in San Benito County, California. Investigators found that numerous wild pigs thrived alongside grazing cattle in the riparian habitat of a cattle operation near a spinach field.


According to the FDA, all connections between specific bags of spinach and individual victims of the outbreak were traced to Dole bagged spinach packed by Natural Selection Foods, San Juan Bautista, California. On September 15, 2006, Natural Selection Foods initiated a voluntary recall of all the spinach brands it packs (both conventional and organic). Visit the FDA website for further information.


CCOF Press Release: CCOF Defends Organic Agriculture Against Attacks
“The tragic outbreak of E. coli O157:H7 in spinach that has killed one person and sickened nearly 200 others in 25 states, is being mistakenly linked to organic farming practices,” said CCOF Executive Director Peggy Miars. “Our sympathy goes out to the individuals and families affected by the outbreak. I’m concerned that misinformation is being spread about the source of the contamination and that organic is being unjustly blamed.”

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Food Irradiation


National Organic Program Regulations and Food Irradiation
Food irradiation is prohibited under USDA National Organic Program (NOP) standards for food production. The announcement by the FDA that allows the irradiation of spinach and iceberg lettuce does effect NOP regulations. Food irradiation will continue to be prhohibited under federal law for organic production.


History of Organic Standards and Food Irradiation

The USDA created the Organic Food Production Act of 1990. In 1997, a first draft of organic standards was created, but failed to exclude what came to be known as the "Big Three": 1) irradiation, 2) genetically modified organisms (GMOs), and 3) sewage sludge. A huge public outcry from the organic community followed with nearly 280,000 comments submitted to the USDA in response to the NOP’s inclusion of the Big Three. The government could not ignore the reaction of the public -- the largest number of comments received by the USDA for any issue EVER. In 2000, a revised draft of NOP regulations eliminated the Big Three from organic agriculture. In 2002, these revised federal standards came into law under the USDA National Organic Program.


For Further Reading on Food Irradiation
“Nuked Food”- The Dangers of Irradiated Food”. George L. Tritsch PhD.


“Nuclear Lunch: The Dangers and Unknowns of Food Irradiation”. 1997. Meeker-Lowry, Susan and Jennifer Ferrara.

“The Unknown Dangers of Food Irradiation”. October 2002. John C. Hanseman.


“Irradiation of Foods Dangers & Preservation: Pros & Cons”. 2002

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