Congress passed the Food Safety Modernization Act (FSMA) four years ago, shifting the focus from food contamination response to active prevention. FSMA represents a dramatic overhaul of food safety standards in the past 70 years — but there are some worrying gaps for urban farmers and water-based growers in particular. Get the facts below, and click here to get our full set of comments to the FDA on the issue.
Environmental Impact and Water-Based Growing
FDA’s Draft Environmental Impact Statement was recently released for public input. It discusses some of the potential environmental and socioeconomic impacts of the measures being suggested under FSMA. However, the FDA missed some important issues for the urban agriculture and hydroponic and aquaponic farms. These systems are growing rapidly nationwide, and becoming a bigger and significant part of U.S. agriculture. It’s not fair or appropriate to try to fit water-based growing and urban agriculture into rules meant for much larger, often rural soil based farming.
Recirculating Farming – hydroponics and aquaponics
Recirculating farm technology has been continually growing over the course of the past 35 years here in the U.S. These water-based farms function in closed-loop systems that make things getting into the farm, like contaminants and diseases very difficult, and as such, can often operate without the antibiotics or other chemicals that can pose a potential threat to consumers’ health. They’re also energy-, space- and water-efficient.
Long story short, recirculating farms shouldn’t be punished for their unique and innovative practices by being grouped in with other farming techniques with different risks. However, FSMA does not account for the important ecologic, social and economic role of recirculating farms.
The Environmental Impact Statement also doesn’t take into account the growing urban agricultural sector. In the future, both traditional and water-based farmers will continue to emerge and expand across the U.S., but if the changes to FSMA pass in their current form, urban and recirc farms will almost certainly be hampered by unfair restrictions and lack of clear regulations for growing.
E.Coli, Food-Borne Illnesses and Recirculating Farm Technology
The FDA defines “agricultural water” as the “water that is intended to, or likely to, contact the harvestable portion of covered produce” or food contact services. In short, it’s the water that’s used for overhead spray irrigation — not the water used to hydrate a plant’s roots. Many outbreaks of E.Coli and Salmonella in the U.S. have been due to spraying contaminated water over fields of leafy greens like spinach or romaine. Naturally, a large part of the FDA’s concern is preventing agricultural water from contact with fresh food.
However, in the context of recirculating farms, water containing fish waste fertilizer is not intended or likely to come into contact with the harvestable portion of the plants. Second, fish waste does not contain E. Coli, and therefore the microbial testing proposed by FDA ijust doesn’t fit with water used in aquaponic systems.
Recirculating farms are different, by their very nature, than other forms of field soil-
based agriculture. Nevertheless, the DEIS completely fails to recognize the differences between soil and water based agriculture — a factor that could be disastrous for the growing number of recirculating farmers.
The RFC is continually working on this issue, submitting comments to the FDA and raising awareness of the possibilities of water-based farming. Want to get involved? Contact our Policy Counsel today to find out how you can make a difference for farms and farmers around the country.