NLGMA Comments — Judith Redmond

Judith Redmond
Co-owner, Full Belly Farm
250-acre organic farm
Guinda, CA

I think that the proposed National Leafy Greens Marketing Agreement is an innovative way to use the marketing act to address the challenges of new food safety legislation and increased federal oversight. Members of the agreement will have a greater level of organizational support, and even a buffer between their farms and the inspectors. However, I do have a few concerns. In California, the marketing agreement is governed by some of the largest processors and handlers, many of whom already have developed their capacity to respond to food safety concerns and market themselves effectively to the public. However, there are many smaller farming operations that will also need assistance in meeting the new requirements, and I don't think it is beneficial to have barriers that fall disproportionately on one sector of the industry.

Our operation is very diversified, and we also benefit from several on-farm plantings of native vegetation that provide habitat for pollinators and beneficial insects. In addition, we use compost, animal grazing, and cover crops to develop soil that is high in organic matter and microbial activity. Unfortunately, food safety rules have developed in a way that discourages wildlife values, water quality stewardship, and the integration of livestock with vegetable production.

We are concerned that new FDA, GAPs, and the marketing agreements could legislate change in our production practices without scientific justification.  We sincerely hope that the agreement will reduce foodborne illnesses traced back to leafy greens. Our fear is that it will lead to additional consolidation in the leafy greens industry due to the difficulty faced by farming operations that are not members of the agreement, to develop the administrative capacity needed to implement the new rules. Note that our focus should be on legislation coming out of Congress and how new GAPs will affect the industry. The [national] agreement will most likely be a way for the industry to implement those GAPs.