Food Safety Certification: A Wellspring of Absurdity

If the Food Safety Regime ever declares spiderwebs to be a contaminant, we will have no choice but to start a rebellion.

It is possible to live a good life on a small income; however, it is not possible to live any kind of life in thrall to absurdity. That is why we would classify the Food Safety Regime in Canada as an “existential challenge” to our food system - because of all the things which make being a farmer difficult, it might be the one thing that threatens most to push us out of this career.

Of course, every farmer recognizes the importance of food safety as a general concept. Speaking through the voices of industry organizations, farmers have consistently shown their willingness to adopt sensible farm practices that prevent contamination of the food we produce.

That being said, the first thing you need to know is that the Food Safety Regime in Canada is not a federally regulated set of standards. It is, rather, a set of standards that is imposed on farmers by corporate grocery stores, working through various bureaucracies that accept input, nominally, from farm industry organizations. If you’ve read our other posts, you may already have some inklings about how this situation could be problematic for farmers and, by extension, our food system.

Farmers who sell their produce wholesale are increasingly being forced, through the demands of large retailers, to certify their operations according to one of several food safety certification bodies. In other words, we are compelled to pay for the “privilege” of selling what we produce to a set of monopolistic retailers. This process is expensive - in our experience, thousands of dollars each year - and is paid for entirely by the farmer. In addition to the direct costs of certification, farmers spend weeks of unpaid time every year doing the most mind-numbing work imaginable: preparing for audits and maintaining sets of written records. While we acknowledge that keeping written records is an essential farm practice, in our experience, the one-size-fits-all paperwork required by the Food Safety Regime is at best redundant with respect to the farm-specific records we already keep.

To be clear, some Food Safety standards are sensible and warranted. For instance, we believe that all farmers should indeed be required to keep detailed records of chemical inputs and fertilizers used on the farm, and that these should be reviewed annually by a third party to make sure that all regulations, such as preharvest intervals (PHIs), are respected. (FYI: The Food Safety Regime is redundant in this respect for organic producers, whose inputs records are already reviewed annually as a component of organic certification.) Does it really make sense, though, to pay Food Safety Certifiers to come out to our farms, in-person, to check these records? Why not just have all farmers submit their completed records to a central location for annual review, such as the Pest Management Regulatory Agency (PMRA), with random spot checks to ensure compliance? Doing so would allow the PMRA to track the use of agricultural chemicals over time and space, something it has expressed a need for but is currently unable to do.

Other food safety standards can be problematic. For instance, our Food Safety Regime makes certain sustainable practices impossible. The long-established practice of allowing chickens to exist in fruit orchards (“chicken tractors”), for instance, faces severe limitations under our Food Safety Regime. According to food safety standards, every day that chickens are out in the orchard is considered a “manure application” (requiring a unique entry on a particular form!). Since manure cannot be applied to the ground in an orchard within 120 days of harvest, this means that chickens are excluded from the orchard for most of the growing season.

The Food Safety Regime also makes it very difficult (practically and/or financially) for farmers to integrate agritourism into their operations, as any person who enters a “production site” is considered to be a walking, talking source of potential contamination. The demands of food safety compliance appear to put agritourism out of reach for most farmers who produce food for the wholesale market (in other words, the farmers who produce the bulk of the food we eat). This is one of the reasons we get frustrated when we hear BC politicians expressing to farmers that if times are tough, we should just integrate agritourism into our operations. Clearly, we have a lot of work to do when it comes to educating our politicians about the realities of producing food today.

Other food safety standards make the farm workplace less safe for workers. When setting up and moving ladders on the orchard, for example, it makes sense that food safety standards forbid us from touching the top of the rungs of a ladder. (The top is where we step, after all, and soil is a potential contaminant.) However, every food safety expert we have ever asked interprets the standard to mean something stronger than this - namely, that we are also forbidden from touching the bottom (or underside) of the rungs of a ladder as well, even though it does not come into contact with feet or soil. Now, if you’ve ever tried to set up a 20 lb orchard ladder by only touching its sides (while carrying up to 15 lbs of apples on your belly), especially on a hill, you can begin to understand the level of safety hazard, physical hardship, and reduced productivity that is introduced by this particular standard.

Still other food safety standards introduce large volumes of waste (e.g. excessive mandated use of hand wipes and sanitizer) or reduce worker productivity and wellness (e.g. workers have to store water bottles in break areas away from where they are working). When I was a kid, we used to pick up windfall apples and put them in their own bin to be sold for juice; now, if an apple touches the ground, it is assumed to be contaminated. Within the Food Safety Regime as we have experienced it, no amount of washing can restore a windfall apple to its rightful status as food.

Finally, it is worth bringing up the fact that our notion of “food safety”, here in Canada, is in conflict with what science is beginning to understand about the degree to which human health is dependent on having a healthy and diverse gut microbiome. From the perspective of food safety standards, food is perfectly safe when it is perfectly sterile. Unfortunately, while sterilization does indeed kill off bad microbes, it also kills off good ones — to the detriment of our gut health. There are also profound ecological consequences to increasing the level of sterilization in the environments we come into contact with. Studies have shown, for instance, that sterile indoor environments tend to contain low diversity in microbes. This lack of microbial diversity, in turn, is one of the factors that gives rise to the evolution of “superbugs” - thereby requiring the use of more sterilization (and so the positive feedback loop continues…). This tension between food safety and food health is not being talked about at the level of food safety policy - but it should be.

If you haven’t yet been convinced that our Food Safety Regime is absurd, we have one more shot left in the barrel. Once our apples leave the orchard, they get shipped to a packing house, where in the course of being graded and packed into boxes for eventual sale, the apples are fully submerged in water. This should make you wonder: is it even possible, after apples have been submerged in water offsite, to be sure that a contaminant discovered on our apples originated on our farm? If not - why are we doing any of this?

None of this has to make any sense, though, because Canada’s Food Safety Regime has evolved into a system that’s primary purpose is less about protecting consumers, and more about downloading the total liability (and costs) of ensuring that food is “safe” onto farmers. Imagine how much more efficient the Food Safety Regime could be if, rather than requiring that farmers micromanage every single physical interaction they have with what they produce (and recording these interactions in arbitrary levels of detail), retailers were just required to meet a certain standard for washing produce before it was put out onto shelves. It seems to me that with this simple change, the Food Safety Regime could be drastically reduced in size and scope. However, this change would shift costs away from farmers and onto the major retailers. It would also reduce the workload of entrenched certification bureaucracies. Therefore, we can expect it to garner significant push back from these powerful players.

And need we remind you that all of this is happening at a time when the retailers are making record profits, while farm profitability is in crisis?

Maybe I’d feel better about the whole thing if someone could point out to me one incident, in the history of the World, where a shipment of apples had to be recalled because a worker touched their face and didn’t immediately run to the nearest wash station so they could clean their hands in one of the two specific ways that the standards allow:

(1) Wash hands with soap for at least 20 seconds; then wipe with a paper towel.

(2) Wipes, followed by sanitizer.

By the way - touching your face during work is classified as a “minor food safety deviation”. A worker is required, according to the standards, to correct a minor food safety deviation immediately - in this case, by washing their hands and discarding any apples that might have come into contact with their soiled hands - and then to promptly report it to the Food Safety Coordinator (me, the farmer) so I can record the deviation on a particular form.

DO YOU FEEL THAT YOUR FOOD IS SAFER NOW?!!!!!???!?!?!??!?!?!?

By Katie Sardinha