E. Coli is no laughing matter and for that reason, the Food and Drug Administration is right to put extra effort into keeping the bacteria out of the nation’s food supply. The vehicle for addressing the problem is the Food Safety Modernization Act, which has many good standards for how our sustenance is handled prior to arriving in our kitchens — and our guts. Some of the proposed rules, while well-intended, will have unworkably burdensome ramifications for small-scale farming operations.
Of particular concern are proposed rules governing water used to irrigate crops. The FDA is considering two standards — one that would allow no E. Coli at all in irrigation water, and one that would have no more than 235 colony forming units, or CFUs, per 100 milliliters. To determine this, farmers would have to conduct frequent — perhaps weekly — testing. Doing so is costly, and the threshold is so low as to be onerous; for comparison, the state of Michigan does not become concerned about its swimming water until levels exceed 300 CFUs, and even that is derived from a mean, of three samples — one could exceed that level if others were lower.
This is a challenge for farmers in this region, particularly those running small-scale operations. Surface water — that which flows in rivers, streams and ditches, runs the risk of coming into contact with various bacteria, including E. Coli. Ditch companies routinely test for contaminants, but the FDA would like to up the ante by requiring stringent testing and application procedures for farmers. It is to high a threshold and the agency should consider a more practical set of rules.
To his credit, Sen. Michael Bennet is asking the FDA to examine the on-the-ground ramifications of its proposed rules on water as well as those governing various soil amendments. He has invited the FDA to visit Colorado; it would be a trip worth taking. The best intentions that inform a policy’s draft can have drastic and unforeseen in the implementation, and are more likely to do so if the proposal lacks comprehensive context. The FDA has more work to do and should accept Bennet’s invitation.
http://www.fda.gov/downloads/Food/GuidanceRegulation/FSMA/UCM360242.pdf
