Our official comment on the FDA’s FSMA proposed produce rule

The Food & Drug Administration (FDA) was mandated by the Food Safety Modernization Act to provide “science-based” standards for production of safe food. The rule that most concerns our farm is open for comment through this Friday November 15; the rule is known as “Standards for the Growing, Harvesting, Packing and Holding of Produce for Human Consumption.” We don’t think highly of it, for many reasons including that it does little more than to promote the paranoid Pasteurian paradigm, essentially suggesting that the solution to food safety is to kill more microbes.

See our post from yesterday for some “highlights” of the proposed rule, as well as websites of organizations that provide good advice on how to comment.

The text of our official comment to the FDA follows:

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The Stanford organic study: Bad science, terrible reporting

There’s been a lot written about the so-called Stanford organic study,  that peer-reviewed journal article that came out around Labor Day. The study generated a flurry of headlines to the effect that “Organic food is no healthier than conventional food” (to cite an example from U.S. News and World Report).  I finally got my hands on a copy of the journal article and read it. There’s a lot to say about why the study is bad, and much has already been written (for example, Mark Bittman’s analysis here and another good one from the New York Times here). However, nothing I’ve read so far has mentioned one glaring problem that explains why headlines such as the one cited above are complete bunk and a disgrace to science. Coming at this from a background as a professional scientist, I’m going to address this particular point.

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Earthquake notes

Stepping off the farm soapbox for a minute, I’m going to don my ex-geologist hat for a few observations on the horrific earthquake/tsunami situation unfolding in Japan:

1) This was not an “unimaginable” event, as so many in the media are claiming. Generations of geologists and scientifically educated laymen have known perfectly well where most seismic and tsunami hazards exist. They do their best to inform decision-making at the political and economic level, with some success. Japan is one of the most prepared countries in the world, and despite the horror, it shows. Sometimes you just can’t prepare enough; there’s a cost-benefit analysis that goes into all decisions. For example, seismic tsunamis are possible along the Atlantic coast, too, but at a low enough risk not to justify investing in the spectacularly expensive mitigation strategies that would be necessary. If it happens, the hindsighters will scream, but no one can pre-justify the expense on a rational level.

As another example, Japan has put tons of money into building some tsunami walls in what are considered the highest-risk areas. This wasn’t one of them, but that doesn’t make them wrong. No country has the resources to attempt 100% prevention/mitigation, so you choose the best solution you have and hope for the best. That didn’t happen this time; we don’t always have control. But it was plenty “imaginable” to anyone who has taken a well-taught earth science course.

2) Big earthquakes happen regularly. This very useful USGS page demonstrates that magnitude 8+ quakes have occured on average a little less than once a year since the record begins in 1902, with rarely more than a couple of years between 8+ events. Most of them happen in remote or unpopulated places, as one would expect given the actual density of human population as spread across the entire globe (including oceans). Every now and then one hits where there are lots of people, and that’s when we pay attention. That’s the reality of statistical chance, not something unusual or unimaginable. This is why most Pacific Rim countries have invested in a network of earthquake/tsunami sensors and warning systems, which performed very effectively in tracking and monitoring this event as it spread, and made sure the effects on further coasts were minimal. The Pacific NW coast is strung with tsunami warning signs, sirens, and evacuation plans. Most residents know what to do in the event those go off (whether they actually do it is their problem, as it their choice to live and build in a risky area). It doesn’t do much good when the event happens a few minutes off-shore, but the system is there for a reason.

3) Subduction zone earthquakes are not, repeat NOT, related to human-induced climate change (I’m talking to you, Grist). That whole climate change debate has gotten to the point where both sides look silly for claiming that either everything, or nothing, is evidence of climate change. Yes, a significant rise in sea level will make a given event more damaging. And, yes, climate (especially precipitation) may influence tectonics on broad spatial scales and long time scales. But subduction zone earthquakes and the tsunamis they generate are about the last place that such an effect would be seen. Activists, please don’t use such bad examples to undercut any chance you had at seeming rational and educated.

4) Media are even dumber than I realized. I was forced to watch CNN in a waiting room Friday morning, and was appalled (even with my low expectations) by how utterly uneducated and alarmist the talking heads were. Even their so-called on-staff scientist was spouting claims that were not only wrong, but flatly contradicted by statements already available from reputable sources (for example, that huge waves were sweeping toward the American coast when NOAA had already issued its forecast earlier that the effects on the Pacific NW would be noticeable but not widely damaging). I haven’t watched TV news in at least 7 years, and I don’t seem to be missing anything.

5) Natural events aren’t always predictable, but they are “expectable”. So while we’re all justifiably horrified at the unfolding events in Japan, let’s take a deep breath and accept that this kind of event happens and is going to continue to happen no matter what we do, on a geologically active planet with ever-more people concentrating with ever-more infrastructure to be destroyed by random but expectable events. And for local readers, keep in mind that St. Louis is on the edge of one of the highest seismic-risk areas in the lower 48, the New Madrid fault zone. It may not happen through our grandchildrens’ lifetimes, but no one should be surprised if it does.

Microbes, Medicine, and Agriculture

“It’s time for a new, conservation-minded view of the microbial communities that live on and in us”

With this tagline, an article in the current issue of American Scientist nicely captures an argument that is fundamental to organic farming, though the authors never directly make the connection to agriculture. The piece describes the complex interactions of microbial activity within the human body, a system medical science is only beginning to really understand. A series of fascinating details emerges through the piece, discussing the incredibly specialized microbial communities (“The skin on our right forearm, for example, harbors a different microbial community than that of our left forearm”) that work together to produce a functioning whole.

Once establishing the importance of these communities, the authors go on to discuss their fragility, and how easily the human body’s functions can be disrupted if the microbial community is disturbed. Naturally, this leads to a discussion of the role antibiotics play:

“Because antibiotics kill bacteria indiscriminately, collateral damage far exceeds target destruction, and our microbial supporting cast is decimated in pursuit of the pathogen. Under the old view of human-microbe interactions, we accepted this collateral damage as a small cost to pay for ridding ourselves of bacteria. Under our proposed ecological model, however, we can understand that we no longer need to destroy the village in order to save it. Broad-spectrum antibiotics are properly seen as agents of major perturbation. Recent studies make clear that antibiotic exposure reduces the diversity of resident microbial communities and makes it easier for pathogens to invade.”

The basic argument being made here is very applicable to agriculture as well. Soil, too, is a very complex chemical and biological system, hosting an incredible diversity of microbial life that is integral to balancing and maintaining soil health. At the core of organic agricultural methods is the principle that nature has created a very dynamic, stable system that we are best off supporting rather than replacing. Instead of reducing soil and plant nutrition to just a few key elements (N-K-P), organic agriculture seeks to maintain the soil as close to a natural condition as possible. Instead of relying on herbicides and pesticides to eliminate all problems, organic agriculture seeks to maintain a healthy balance of pest and predator. In the same way that it’s worth being sick now and then to strengthen the immune system, it’s worth having some pests and weeds because they’re integral to the larger health of the soil and the ecosystem. I’ve seen many reports that medical researchers feel people are weakening their immune systems due to over-reliance on drugs; the same dynamic happens in soil that is regularly disturbed, sterilized, and chemically imbalanced by artificial inputs and treatments.

In addition, the over-use of artificial substances (whether antibiotics or farm chemicals) can actually be directly counter-productive by encouraging the development of resistant strains of bacteria, weeds, or pests. No spray can kill 100% of all pests or weeds, just as no drug can destroy 100% of harmful bacteria. The inevitable result is the survival of the few individuals whose genetics gave them more resistance, and over time these strains can become far more problematic than the original concern. This is actively happening in both the medical and agricultural worlds.

The author notes that “In much of the developed world, and certainly in the United States, we appear determined to make the planet microbe-free. The advertising, pharmaceutical and home-products industries have tried to persuade the public that every microbe is the enemy. But the more we learn about the biological world, the less this perspective makes sense.” The same dynamic is present in agriculture, and the result is ever-more reliance on artificial inputs as the natural ability of the soil and ecosystem to maintain a healthy balance is undercut.

I could go on for pages (I haven’t even touched on the obvious implications for antibiotic use in industrial meat production), but hopefully this demonstrates the underlying connections that can be made across the board. Organic farming is often characterized as an unscientific, pseudo-pagan, Earth-Mother belief system characterized by mythology rather than science, and this reputation is earned in some circles. However, the perspective we take is that true organic farming is deeply rational and scientific when approached with the philosophy outlined in this article; that we are best off understanding and working with the complex natural systems already available, rather than attempting to engineer a new reality without understanding what we’re replacing.