Conservation enhanced product tracing abilities, and additional recordkeeping

    Conservation is a significant tenet of American society. A conservation ethic emphasizes the management, protection, and restoration of natural resources for public benefit, including sustainable economic and social utilization. In spite of broad recognition of the significance of natural resource conservation, it is of utmost importance that we substantiate the outcomes of conservation programs in a time of increasing fiscal responsibility and accountability. On average 48 million people get sick, 128,000 hospitalized, and 3,000 die from foodborne illnesses associated with poor produce habits. To eliminate the risk of illness from food products, President Barack Obama signed into action the Food Safety Modernization Act (FSMA) on January 4th, 2011. The Food Safety Modernization Act requires the FDA to develop regulations directed at improving the safety of produce. The FDA is required to include standards for “animals in the growing area” when developing new produce safety and regulations; they must be, “…consistent with ensuring enforceable public health protection, conservation, and environmental practice standards and policies established by federal natural resource conservation, wildlife conservation, and environmental agencies….” The Food Safety Modernization Act recognizes that preventive control standards improve food safety only to the extent that producers and processors comply with them. The FSMA also recognizes that the Food and Drug Administration must have the proper tools to respond effectively when issues emerge despite preventive controls; these include: mandatory recalls, expanded administrative detention, suspension of registration, enhanced product tracing abilities, and additional recordkeeping for high risk foods. The Food Safety Modernization Act provides the FDA with unprecedented authority to ensure that imported products meet U.S. standards and are safe for consumers. The FDA must take into consideration importer accountability, third party certification, certification for high risk foods, voluntary qualified importer programs, and the authority to deny entry. Not only does the Food Safety Modernization Act provide affirmation that our families are ingesting healthy food products, but it also provides a system of collaboration with other government agencies, both domestic and foreign. The statue explicitly recognizes that all food safety agencies need to work together in a “…integrated way…” to achieve public health goals. To enhance the safety of produce processes, the Produce Rule was created, as an extension to the Food Safety Modernization Act. The original proposal did not proactively support practices that benefit both conservation and food safety objectives. Apart from developing standards for domesticated and wild animals, the proposed regulations did not incorporate conservation considerations directly into the regulations. After revising and rewriting, a new Produce Rule was established. The revised Produce Rule proposed regulations included in a new provision intended to avoid “…inadvertently promoting and encouraging practices that adversely affect wildlife and animal habitat, including impacts on threatened or endangered species….” The newly established provision would be a constituent of the regulations themselves, which would specifically state that there is nothing in the Produce Rule that requires “…covered farms to take measures to exclude animals from outdoor growing areas or drainages…,” a significant improvement from the original draft. The Produce Rule would detail new standards for the growing, harvesting, packing, and holding of produce for human consumption.The new provision explicitly details the standards farming personnel must uphold for produce that may be consumed. Farmers are required to ensure that water that is being produced for human consumption is of adequate sanitary quality, with inspection and periodic testing requirements. Farmers must also specify types of soil treatments, methods of soil application, and time intervals between application of certain “…soil amendments…”; this includes records of manure and composted manure and crop harvest. Farming personnel is required to follow hygienic practices–i.e handwashing, not working when ill, and maintaining personal cleanliness. Farming practices must respect wildlife and is required to abide by certain measures, such as waiting periods between grazing and harvesting, if there is reasonable probability of contamination. Farmers must monitor for wildlife intrusion and not harvest when produce is visibly contaminated with animal feces. The new provision also requires training for supervisors and farming personnel who handle produce. Accompanying these requirements and standards are recordkeeping requirements that document adherence to these standards; including for training, agricultural water, biological amendments of animal origin, and health and hygiene. The Food and Drug Administration acknowledges that it supports and encourages co-management; this implies that farming personnel would simultaneously achieve conservation targets and reduce pathogen hazards associated with food production. The FDA’s approach to farm management is to respond to site-specific conditions by integrating cultural, biological, and mechanical practices that promote ecological balance by conserving biodiversity, soil, water, air, energy, and other natural resources. Although the Food and Drug Administration express their support for co-management, they do not include a clear explanation of co-management in the proposed rule and overlooks numerous opportunities to develop conversation considerations into standards. To strengthen co-management with farm personnel, regulations would need to be defined and include this concept directly. There is absolutely no denying that a measure of sustainability must now be incorporated into our conservation endeavors, due to financial and time pressures, habit, and changing opinions regarding tolerable conditions for collections. Conservators must now consider not only the interaction of materials and the environment, but production use and disposal of materials employed in work. We must educate, become more aware of our contribution to pollution and waste and implement more sustainable practices. Conservation practices are central to organic production systems.  The National Organic Program requires that organic farmers conserve biodiversity and protect soil, water, wetlands, woodlands, and wildlife.When drafting the Food Safety Modernization Act, Congress included provisions to reduce the paperwork and recordkeeping burden of new food safety regulations. Congress required the FDA to comply with the “Paperwork Reduction Act(1)” and minimize the burden of paperwork and recordkeeping. The FSMA prohibited the FDA from requiring that farms and numerous other food facilities hire outside consultants to write food safety plans and from duplicating the requirements of the National Organic Program regulations. As of the present, there are no traceability requirements mandated of raw agricultural commodities, such as fruits and vegetables. The records must facilitate verification and compliance with standards and identify that there is a pattern of occurring issues important to reduce the likelihood of contamination. The FDA’s records must also be maintained with detailed information, minimizing the risk of contamination and demonstrates compliance with the standards. The FDA requires farmers to establish and keep records to show compliance with standards associated with the Produce Rule. Farming personnel must record the name and location of the farm, values and observations collected during monitoring activities, and an adequate description of the produce applicable to the record, location of the the growing area, and the date and time of task that was performed or observed, which must be accurate and legible; it must be dated and signed by the individual performing the task. In addition to documenting compliance with the standards, the FDA requires farmers to document actions taken when one of the standards is not met. The Food and Drug Administration requires that a supervisor or responsible party sign certain records, including records documenting testing, monitoring, sanitizing, and corrective action activities.The FDA is proposing that farmers keep records for two years past the date the record was created, and that farmers “…retain records documenting the general adequacy of equipment and processes for at least two years after the equipment or process was last used….” Conservation practices are significant to decreasing food safety risks on farms. Buffer strips, grassed waterways, and wetlands help keep our water supply clean by reducing the amount of pathogens, nutrients, and pesticides into streams, lakes, and rivers. Conservation practices also protect wildlife. That habitat can support insects that prey upon pests, raptors that serve as animal control, or other species that reduce the need for toxic chemicals to control agricultural pests. Despite these benefits, conservation practices–particularly those that encourage wildlife–have been seen as a potential threat to produce safety. After an outbreak of the pathogen E. Coli was traced back to a farm on California’s central coast in 2006, the industry responded by developing new food safety regulations. While the outbreak was not traced back to wildlife, these industry standards encouraged producers to remove conservation practices that had implemented their farms–including those installed by government encouragement and assistance–and build up fences or other structures to prevent wildlife from roaming amongst their field. While there has not been any scientific revelation that wildlife has contributed to these outbreaks, farmers have been encouraged to prevent domesticated and wild animals from being on their property. To ensure that these requirements were being abided by the Food Safety Modernization Act was established.     Producers and processors must consider the benefits and disadvantages of a tillage system before changing systems. The most significant benefit of conservation tillage systems is significantly less soil erosion due to wind and water. Other benefits include reduced fuel and labor requirements. However, increased reliance may be placed on herbicide labels with certain conservation tillage systems. Conservation practices are ideal because they increase overall productivity.  Agricultural conservation improves soil structure and protects the soil against erosion and a loss of nutrients by maintaining a permanent soil cover and minimizing soil disturbance. Because land no-till is not cleared before planting and involves less weeding and pest problems following the establishment of permanent soil cover and crop rotations, farmers in Ghana have reported a 22% savings in labor associated with corn production. Similar reductions in labor requirements have been reported with no-till rice-wheat systems in South Asia and in South America; much of the reduced labor comes from the absence of tillage operations, which use up valuable labor days during planting season. Agricultural conservation requires significantly less water use due to increased infiltration and enhanced water holding capacity from crop residues left on the soil surface. Mulches also protect the soil surface from extreme temperatures and significantly reduces surface evaporation. In sub-saharan Africa, as with most dry locations, the benefits of agricultural conservation are most important during drought years, when the risk of crop failure is greatly reduced due to enhanced water efficiency. Soil nutrient supplies are enhanced by biochemical decomposition of organic crop residues at the soil surface that are vital for feeding soil microbes. While much of the nitrogen needs of primary food crops can be met by planting nitrogen-fixing legume species, other essential nutrients often must be supplemented by additional chemical or organic fertilizer inputs. Farmers have reported higher yields with much less water, fertilizer, and labor inputs, therefore resulting in higher overall farm profits. In Paraguay, net farm income of no-till farming on large scale commercial farms increased from $23,467 to $32,608 more than farms using conventional tillage over a ten year period. Agricultural conservation represents an environmentally-friendly set of technologies; because it uses resources more efficiently than conventional agriculture, these resources become available for other uses, including conserving them for further generations. Reduced applications of agrochemicals also significantly lessens pollution levels in air, water, and soil. Conservation tillage may require the application of herbicides in the case of heavy weed infestation, particularly in the transition phase, until the new balance of weed populations in established. The practice of conservation tillage may also lead to soil compaction over time; however this can be prevented by the employment of chisel ploughs or subsoilers. Initial investment of time and money along with the purchases of equipment and herbicides will be necessary for establishing the system. Higher levels of surface residue may result in higher plant disease and pest infestations, if not properly managed.

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