FSEA's fake HACCP requirements will do to small and what's left of medium produce farmers what Taylor's meat and poultry fake HACCP rules did to small and medium meat slaughterers and processors.
Under HR 2749, farms, now redefined as "facilities, would be required to maintain extensive records demonstrating their compliance with standards and make these records available to auditors. If a facility's records failed to meet "performance standards, whatever those are determined to be, the food "grown, harvested, processed, packed, sorted, transported, or held under conditions that do not meet the standards, would be considered adulterated (Sec. 104 (a)). So, even if a farm's or "facility's food was perfectly safe, it could be considered in violation of the act and subject to substantial fines and see its product confiscated, if merely some element of it's paperwork was out of order.
Does This Pass the Smell Test?
If HACCP is not appropriate for application to the farm as Dr. Sperber maintains, why is it being forced on farmers? Is this really all about food safety?
Why should farmers be subject to so many burdensome costs, from a non-progressive $500 registration fee to the costs of tracing technology and extensive, expensive testing technology? Why wouldn't Congress fully fund the program, relying instead on fees, fines, and criminal judgments to fund it, if it were serious about food safety?
One farmer with professional knowledge of what's required to create and maintain a HACCP plan says it would take him 100 hours to create a plan for each type of food processed plus two hours each production day to maintain it. Laboratory costs would be $15,000 just for microbiological testing.[30]
Microbiological testing isn't going to be the only business platform in line to profit from HR 2749's requirements. Forbes Magazine recently ran an article describing the bundle that will be made by businesses that make products to relieve consumers' fears. To satisfy the bill's traceability requirements, farmers may find themselves hit with a bill of $20,000 for tracing software. [31]
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