There were lots of comments on this blog regarding my recent stories about making salads safer. Many of those comments argued that the solution is to grow your own. Or at least buy from local farmers.
Which raises an interesting question: Are salad greens from your local farmer's market actually safer than packaged lettuce from thousands of miles away? And should the same safety rules apply to both?
The answers aren't obvious, even to the U.S. Food and Drug Administration, which is struggling to draft safety regulations that will apply to most vegetable growers.
One thing is obvious, though. Right now, when it comes to food safety, big and small vegetable farmers are living in different worlds. And if they all are forced to live by the same rules — if the FDA asks everyone to behave like big-time California-style growers, for instance — it will be a shock to many smaller farmers in other parts of the country.
I recently toured some vast fields of lettuce and an enormous salad processing plant in Salinas. The plant, runs by , handles 10 million pounds of salad greens every week. Those greens go out the door in sealed plastic bags, and they're consumed all over the country.
Because of sheer scale of this business, and the potential damage from any large-scale contamination, businesses like these take extreme measures to keep Salmonella and disease-causing E. coli bacteria from getting into their greens.
Then, back home in the east, I stopped by in Clinton, Md., a family-run operation that sells some of its home-grown kale, collard greens, tomatoes and cabbage at farmers' markets, but delivers most of its production to local grocery stores.
Phil Miller took time off from filling a local church's order for Easter flowers to show me around his fields. He grew up on this farm together with a whole tribe of cousins. His mother, uncle, and aunt still live here, and they own the land. He now lives a mile or so down the road.
"We love it here, and we are making a living. We're doing better now than when were were growing tobacco," Miller says. The family started phasing out of tobacco production in the 1970s.
Miller has been learning a lot about food safety rules lately. He's trying to earn a food safety certification, called GAP certification, from the Maryland Department of Agriculture. GAP stands for Good Agricultural Practices, and many food buyers are starting to require that their suppliers get this certification.
"They've had a young lady come out and she's talked to me about how we do this," he says. "Most of it's common sense."
But what's common sense in Maryland appears to be a lot more relaxed than what's required in the Salinas Valley. I look around and see several things that a food safety auditor in California would frown on: grass growing right up to the edge of Miller's fields (animal habitat too close to the food); power lines directly over cabbage plants (danger of bird droppings); a couple of geese standing on the edge of a pond that stores irrigation water.
"The water, I think, is going to be OK, but we will get it tested," says Miller. What's still unclear, he says, is whether he'll have to stop using that water for irrigation if it is contaminated, because he uses "drip irrigation," a system in which the water drips from hoses on the ground directly into the soil, without touching the produce at all.
Miller doesn't seem worried that new national safety regulations will be too onerous. Miller Farms will meet whatever requirements the FDA comes up with, he says. "The bottom line is, we need to produce food that's safe for the American people to eat."
There are others, however, who do worry. Some are concerned that the new rules may make it more difficult to use composted manure as fertilizer. (In the Salinas Valley, organic producer Earthbound Farm doesn't use any compost because of safety concerns. It does use a manure-based fertilizer that's been heat-treated to kill all microbes). Amish farmers in Ohio have also told the FDA they couldn't possibly abide by a rule that excludes all animal intrusion into vegetable fields; they farm with horses.
Because of such concerns, in fact, the new safety rules won't apply to the smallest farms — those that sell less than $500,000 worth of food, or sell it to people who live within 250 miles. When Congress passed the Food Safety Modernization Act in December, 2010, it specifically exempted those farms.
So is that exemption justified? Are small farms less of a concern?
Bill Marler, a Seattle-based lawyer who represents people who've suffered from food-borne illness, doesn't think so. "I think that there's a misplaced belief that small-scale agricuture is somehow inherently safer than large-scale agriculture," he says. "The reason why large-scale agriculture perhaps seems more unsafe is that they are much more easily caught."
Contaminated produce from a small farm, he says, may end up sickening a single family, or just one per person, "and then it becomes incredibly difficult to say whether it was the lettuce or something else that made that person sick."
Yet if the comments on our blog are any indication of consumer sentiment, many people seem willing accept a lower standard of hygiene at a local farm, compared to an "industrial" mega-farm. This is only speculation, but perhaps that difference is rooted in a visceral sense of where the produce comes from.
When you go to a farmers market and someone dressed in overalls hands you some spinach, you may intuitively sense that these leaves came from the dirt, and need to be consumed with care.
And you may have much higher expectations for spinach in a sealed plastic bag in a supermarket. "There's an assumption on the part of many consumers that their food is sterile. And very few of the foods that we eat are sterile," says Robert Buchanan, director of the Center for Food Safety and Security Systems at the University of Maryland.
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