Dear Eaters and Co-Producers 6

Dear Eaters and Co-producers

(all of you who are contributing to the local food and farm economy with your support, both financial and through words of encouragement to direct-to-market farmers –  farmers who are committed to seeing the faces of those that they feed and shortening the “supply chain” of that precious thing that nourishes our bodies and connects us to the earth – FOOD):

Many of you tell us how much you love knowing your farmers, well WE LOVE knowing the people we’re growing for too!

It makes every step of the work we do feel so important….knowing that it leads to food in your belly (and in our bellies too….).  And for that reason, we are committed to ensuring that food is safe.

When we’re harvesting, hydro-cooling (might look like rinsing to you), storing, packing, and even planting and weeding….we have our customers’ faces in our minds. The children, the grandmothers, the ones who are eating our food to help them during a time of great illness, the pregnant ones, the entire families, the ones who are passionate about nutrition, the chefs (both home and professional)…..

Your faces are what keep us working to produce safe food (not to mention nutritious, delicious, beautiful….). That is a stronger motivator for us than any regulation the Canadian Food Inspection Agency (CFIA) could come up with.

Right now (until April 21, 2017), the CFIA is consulting with Canadians on some proposed new food safety regulations (called the Safe Food for Canadians regulations).

These regulations, while serving to streamline food safety regulations for the farms that sell to the big grocery stores or export out of the country, will affect farms like ours disproportionately.

Why? Simply because when we sell to the nearest major city to us, Dieppe (only an hour away from our farm….very short in Canadian rural village to city distances), in order to provide us with the (simple) livelihood we need, we also happen to be crossing a provincial border.

For a farm selling within their provincial border, even if they had 50 employees (we have none – it’s just the 2 of us owner/operators), they could simply ignore these proposed regulations – they wouldn’t apply to them.

And while, we are wholeheartedly committed to following food safety regulations (we’ve created a voluntary food safety plan for our farm, we’ve taken food safety trainings, we keep up-to-date on new ideas for food safety practices, and we plan new infrastructure projects with the knowledge of a global trend toward increasing food safety regulations), the paperwork (keeping a log on when we clean our bathroom?!), and the audit process seems extreme for a farm like ours.

If this is the kind of thing that makes you want to speak up, there’s a sample letter (that you can and should adapt in any ways you’d like….or you can also just sign your name and send it) below. You can send it by post or email: CFIA-Modernisation-ACIA@inspection.gc.ca

Thanks for reading, for caring, and for the huge role you play in our lives.

Your farmers, Shannon and Bryan

Photo that Janet Wallace took at our farm last October while talking to us for her article in the recent Saltscapes magazine.

Canadian Food Inspection Agency

1400 Merivale Road, Tower 1

Ottawa, Ontario

K1A 0Y9

Attention: Richard Arsenault, Executive Director

Domestic Food Safety Systems and Meat Hygiene Directorate

Re: Consultation on Safe Food for Canadians Act proposed regulations

Dear Mr. Arsenault;

The Safe Food for Canadians regulations, as they are currently proposed, greatly increases the regulatory burden for farmers selling direct-to-market (directly to consumers or end users such as restaurants) across provincial boundaries.

Due to the increased transparency, traceability, and close relationships inherent with the direct-to-market model of farming, farmers in this sector are very aware of the business loss they would face in the disastrous event of a food safety situation and already prioritize food safety for their customers (whom they interact with face-to-face on a regular basis).

This is a different model of food access and farm marketing than much of our Canadian food is sold under. While the proposed Safe Food for Canadians regulations may be well-suited to streamlining regulations for many agricultural sectors, direct-to-market farms are unique.

While there is currently an exemption proposed for farms with gross sales of $30,000 or less per year, this sales figure has little to do with achieving any food safety outcomes and arbitrarily affects farms regardless of other factors such as marketing type, product raised, physical size of farm, or number of employees.

We’d like to recommend a change to the Safe Food for Canadians Act Regulations: to exempt all direct-to- market interprovincial sales and let them continue to be regulated as per the legislation in the sold-in province. 

As currently proposed, complying with these regulations would add yearly expenses of around $7000 for any farm that sells its produce directly to local consumers who just happen to be located across a provincial boundary.

It also put direct-to-market farmers who sell locally (but across provincial borders) at a great competitive disadvantage with similar types of farms in their province who don’t need to cross a provincial border in order to support their livelihoods.

In Canada, we have a rich diversity of communities, not all of them fall neatly within provincial borders. Our nation’s capital is a great example of this, with much of the fresh, local produce coming from the Quebec side of the Ottawa River. Our smaller provinces in Atlantic Canada are another great example of communities close to provincial barriers (though every province has examples of these “border communities”).

While we can all support the idea that safe food is a necessity for Canadians, access to fresh local food should also be a top priority.

Please consider how these regulations will impact direct-to-market farms and in turn our rural economies.

Thank you.

There’s another thing about the currently proposed Safe Food for Canadians Regulations…..they’re sticking the Canadian Organic Regulations into them:

As Organic farmers, we are concerned with how the Organic Products Regulations is being stuck under the proposed Safe Food for Canadians regulations. There are a number of things that the CFIA has proposed changing that will affect the majority of organic operators – and for no apparent reason! It’s certainly not for food safety reasons.

Thankfully, some national organic organizations have gone through the proposed regulations with a lot of scrutiny (and some lawyers) because I know that many organic farmers, like us, don’t have the time (or legal jargon know-how) to sort out what it all means.

There’s a national effort to get 5000 people writing in to the CFIA to tell them how (or if) the organic regulations should be incorporated under the Safe Food for Canadians regulations.

While many people think of organic food as safer….they’re often thinking of ‘safer’ as free from GMOs, synthetic pesticides and fertilizers, and sewage sludge….but that’s not what “food safety” means in this context. Organic food is really more of a quality-based set of regulations (based on growing practices), rather than a safety-based regulation (though there are requirements for organic farmers that deal with food safety…specifically around water testing and manure management).

You can read the issues that the Organic Federation of Canada has highlighted (Shannon currently sits on the board), by clicking here.

For us, one of the greatest reasons we would like the Organic Products Regulations to be removed from the Safe Food for Canadians Act is because we would like to see other Canadian products, besides food allowed to be certified organic.

Like what?

Well, we personally grow cut flowers for bouquets. And while we raise them organically, we cannot certify them because Canada doesn’t have Organic Standards for flowers (or any non-food or animal feed product). We also like buying organic body care products….but to do so we need to buy products made outside of Canada, since other countries have organic standards for body care products/cosmetics, but Canada doesn’t. Also fibre (for organic clothing or other fabrics)….right now, even if it’s grown/raised organically, if it’s Canadian, it can’t be labelled as Organic.

Under the Safe Food for Canadians Act, the Organic Products Regulations will continue to include only food. While Canada is in the top 5 countries around the world buying organic products, we will need to rely even more on imported organic products unless we have regulations that allow us to produce more and different types of organic products…..Canadian organic products.

Also: check out this opportunity to make your opinion heard on this issue with a tweet!

CFIA will be joining the Canada Business Network (https://twitter.com/canadabusiness) for a bilingual #SMEPME Twitter Chat next week about the proposed Safe Food for Canadians Regulations and what this could mean for food businesses.

The CFIA (https://twitter.com/cfia_food) will answer your questions about the proposed requirements. Topics will include licensing, preventive control plans, traceability and support available to small businesses. Follow the #SMEPME hashtag.

Topic: Calling all SMEs in the food sector! How would new proposed requirements impact you? http://canadabusiness.ca/events/smepme-twitter-chat-calling-all-smes-in-the-food-sector-how-would-new-proposed-requirements-impact-you
Date: April 11, 2017
Time: 12pm-1pm EDT
Hashtag to follow: #SMEPME

Time is running out! Comment by April 21, 2017. Your feedback is important. Have your say at inspection.gc.ca/safefood