I managed to get to a meeting of the local bee club this week. Bleak. The hive loss this winter in the mid-Atlantic region was epic. It wasn’t just me. Nearly, everyone got hit and hit hard. I’m still not sure if the dead loss prompted the state of Virginia to hire more bee inspectors or whether that was driven by the program the state started this year which pays people to take up beekeeping. Regardless, a long disregarded Virginia law stating thou shalt not sell bees on comb without state inspection is now being vigorously enforced under threat of a $2400 fine and a year in jail.
As for the cause of all the dead loss – nobody knows for sure. Last year’s weird weather certainly put a lot of stress on the bees, which probably opened them up to all sorts of things. Small hive beetles are getting a lot of attention as is the high pH of sugar water.
So the state wants to get into my hives and now I am learning, the Feds really want to get into my bathroom.
The Food Safety Modernization Act (FSMA) – another genius piece of legislation. It’s coming, very quickly now. Are you ready? Recently, the Virginia Beginning Farmers and Ranchers Coalition hosted a webinar on FSMA and I thought I would share the highlights. You can see the webinar here: http://connect.ag.vt.edu/
At the heart of FSMA is something called GAP or Good Agricultural Practices. As food producers, we must all be GAP trained, and then either GAP compliant or GAP certified depending or the size of your operation and whether you retail or wholesale. I have not yet attended GAP training, but I’ve read about the concept. Basically, the FDA is very concerned about how often farmers wash their hands and how they wash their hands and where they wash their hands and where the water used to wash hands goes. They are so concerned they are going to require every farmer to have a policy manual on handwashing.
FSMA also addresses signage, livestock operations with particular attention to water quality issues. Wildlife management (like that’s possible), composting procedures, and the 120 day rule for manure applications. Irrigation and chemical usage are part of the package as well. It goes on: first aid, smoking, eating and breaks, illness and injury, traceability, and in case you missed it, washing of hands.
If you are a direct marketer (sell at farmers markets, roadside stands, run a pick your own farm or CSA, run a restaurant or retail food establishment), then you will need to be GAP Trained and GAP Compliant, which means you have a manual and keep records. If, as a direct marketer, you sell less than $25,000 of food, you are exempt from GAP Certification requirements. If your sales are more than $25,000 but less than $500,000, you will be partially exempt. If you’re generating more than $500K, then you probably aren’t reading homesteading blogs and can afford a FSMA compliance officer. By the way, Certification involves an on farm inspection and the last I read, the farmer had to pay for the inspection.
The law was passed in 2011 and the Feds are still writing the rules, but comment period ends May 16, 2013. Voice your concerns now or forever hold your peace. Final rules will be coming soon.
Bottom line: if you are growing food to sell, you will need to attend a GAP training session in the next year or so and then write your policy manual and then keep records. All on your dime, of course. Of course, this begs the question, if small farmers are exempt from actual certification, then what’s the point of the policy manual and all the record keeping?
Is there any financial benefit for the small farmer in the FSMA? Well, so far there’s no reduction in liability insurance premiums, but being Trained and Compliant DOES ALLOW you to continue to sell your goods.
I realize just about every industry in our country has to deal with its own set of nonsensical regulations, but the general public doesn’t usually starting rioting three days after their supply of nail polish or postage stamps disappears. You would think our glorious leaders would figure out that true food security lies in an abundance of vibrant and productive small and medium-sized farms growing for local markets year round. Yet, we are soon to be saddled with a policy manual and records on what soap sits by the sink, how hot our compost piles are and why we applied a Band-Aid. Honestly, how can there be food safety if the people who are willing to battle weather, disease, insects and “wildlife” are so busy doing paper work they haven’t time to actually grow food?
Rant over. Now, go wash your hands.