Good Agricultural Practices (GAP) regulations on small farmers. [View All]

As small farmers, most of you are probably familiar with the GAP regulations being proposed.

If not, below is a link that outlines the regulatory requirements being considered.

http://www.fda.gov/Food/GuidanceComplianceRegulatoryInformation/GuidanceDocuments/ProduceandPlanProducts/ucm064574.htm

I have some serious problems with these regulations and I think most small farmers will also. It is these burdensome regulations and accompanying fees that are driving the small farmers out of business.

1. The documentation required to satisfy an auditor or inspection. It is extensive and detailed and could take as much time as filling out tax forms. Unlike ConAgra, we can't just write a field number down and say we planted hundreds of pounds of all the same seed, and fertilized it with all the same chemical and sprayed it with all the same insecticide. I plant 14 different types of fruit and vegetables and the organic methods I use are diverse and constantly changing. The burden on most farmers for the maintenances of extensive records can take two or three days out of a week to keep up with.

2. The requirement to keep wildlife out at all times. Does anyone honestly believe ConAgra keeps all those birds from flying over or landing in their fields? Do you really believe they keep all the rabbits and deer out? Yet we as small farmers must spend hundreds to thousands of dollars on fencing and netting to attempt to comply with this regulation.

3. Fees. I have a serious problem with paying for my own inspection. It seems to me to be more like a bribe. I'm footing the bill, the inspector knows that and he will mostly likely side with the person paying his way. I know big corporations like it because it has a built in conflict of interest on the inspector's part. But these constant fees on a small farmer can become very burdensome and wipe out the small profits we usually make.

If you agree, please cut and past this letter and forward to your Representative and Senator. They need to hear from us small guys as well as the huge corporations.

Dear ___________,

I am a small-scale farmer living in _______ County in ______. I raise __ on my farm. I market my __ through _______________________ I market my through
When people hear the words “food safety.” It is something everybody wants. No one wants their food contaminated. However, the currently written “Good Agricultural Practices (GAP)” are an unreasonable burden on small scale producers like myself.

It is common sense for people who work on small farms to follow basic standards of cleanliness, such as washing hands before going into a field to harvest produce and after using the bathroom. I have no problem following these practices and reminding anyone working for me or helping me to follow these practices. But, many of the requirements of GAP are hugely burdensome and frankly, unrealistic.

The paperwork and the documentation of every farming practice right down to tractor maintenance is excessive. I am unclear on how a GAP auditor will handle livestock being raised in the vicinity of my vegetable growing operation. For instance, what constitutes a manure pile? Asking me and my neighbors to not raise animals nearby is not practical in ______________ where almost every farm has some type of livestock. Even more impossible is controlling wildlife. As you know, wildlife is abundant in ______________ and gardening in an area where wildlife lives is already challenging. Keeping wildlife out of the garden or from flying over the garden is simply impossible.

Please know that my family and I are working as hard as possible to produce high quality food for our own and the publics consumption. We take this work seriously and grow food carefully. Please offer amendments to make any food safety legislation work for small-scale producers. For example, allow reasonable buffer strips between livestock and garden areas (the Natural Resources Conservation Service requires a 30 foot wide buffer strip between livestock areas and natural water sources). Additionally, please remove wildlife from the food safety equation. Remember that for thousands of years food has grown and has been produced in the vicinity of animals. Our population has thrived on this food.

I understand that costs are associated with inspections. But passing the cost on to a small farmer and their family could be the difference between making a profit that year or not. The payment of fees to an inspector sets up a conflict of interest. If I pay the inspector a fee wont he be more likely to decide in my favor? Payments like these sound more like bribes. If they are necessary, than spread the cost around to those who can more easily afford them. Those who are being inspected should NOT foot the bill for the inspection where a conflict of interest would occur.

Your help in ensuring the survival of the small farmer will be an important step in preserving our nation's food supply.

Please feel free to contact me if you have any questions.

Sincerely,