Debunking the Need for Provisions in the FDA Food Safety Modernization Act (FSMA)

Simply put, the FSMA is inequitable in terms of its effect and impact on small to medium farmers.

Furthermore, the FSMA is negatively impactful on the millions of consumers that choose local, organic, seasonal, and unprocessed foods.  Most notably on this list is produce, which by its very nature is best eaten soon after harvesting, local to its source.   Finally, the public good (a more healthy populous) goal of FSMA is significantly undermined by the negative impact of diminished access to healthy food.

FSMA Undermines the Right for Citizens to Choose Local, Healthy Alternatives

Arguably, the best source of produce is local, small to medium sized farm operations.   The FSMA puts an unfair burden on these types of operations as compared to larger, industrialized farming operations as those companies have the scale and scope to deal with regulations that would make a smaller operation unprofitable.

FSMA Severely and Inequitably Impacts Local Businesses and Economic Development

Small businesses are the cornerstone of the US economy, creating by far more jobs than big business.  Putting oppressive regulations upon small to medium farming operations is tantamount to their destruction.

Typical comment from a small farmer and/or concerned citizen about small farms and local food:

“As a small farmer I strongly object to the government attempting to apply industrial rules across the board to include farms as small as my 9 acres.  If you’re trying to destroy family farming, you’re on the right track and I can’t help but observe the tendency of “my” government to side with large corporate interests to the detriment of everyone else.  Leave small farms alone and focus on reversing the damage caused by large-scale, industrial chemical and biotech driven agriculture instead.”

FSMA Goal of Safer Food is undermined by Diminished Access to Healthy Food

Ostensibly, the reason for the Food Safety Modernization Act (FSMA) is to improve the overall public good.  More specifically, the reason is to improve the public good through safer food, which leads directly to less food borne illness and fatalities.

The Center for Disease Control (CDC) estimated in 2011 that each year roughly 1 in 6 Americans (or 48 million people) gets sick, 128,000 are hospitalized, and 3,000 die of foodborne diseases.  The number of annual deaths is estimated to be only about 3,000 (with 90% confidence ranging between 1,492–4,983 persons).

By way of comparison, the Surgeon General’s office estimates that about 300,000 deaths per year may be attributable to obesity.  While obesity is arguably only indirectly related to food choice, and the availability and cost of healthier foods is also indirectly related to being overweight, there are other potentially significant health factors that are directly related.

Those directly related health factors pertain to the unknown effects of inorganic foods, which by common definition are those foods and food-like substances that have added substances, such as herbicides or pesticides, and/or have been genetically modified (commonly referred to as GMO for Genetically Modified Organisms) to achieve various economic benefits.  Arguably, the benefits (such crops that release their own pesticide as a result of GMO introduction) are outweighed by the potential ill health effects within the human body.

These factors are unknown because of inadequate testing, unless one considers proliferation of GMO-laden foods a form of mass-testing, especially when put into the context of their existence within many foods not currently identified by law.  In other words, consumers eat foods every day that contain GMO and they are not informed of their existence through proper labeling.  Legislation is underway in certain states (such as the State of Washington) to make it a lawful requirement for GMO labeling.

Leading experts agree that allergies are on the rise.  According to the UCLA Food and Drug Allery Care Center, “The occurrence of allergic disease is skyrocketing, and some estimates are that as many as one-in-five Americans have an allergic condition.”   According to the Institute for Responsible Technology:

  • Scientists have long known that GM crops might cause allergies
  • Unlabeled genetically modified (GM) foods carry a risk of triggering life-threatening allergic reactions, and evidence collected over the past decade now suggests that they are contributing to higher allergy rates

Anyone with a basic understanding of statistics knows that correlation and causation are NOT synonymous.  The classic example is inductive reasoning such as (1) More people die in summertime due to drowning, and (2) More people eat ice cream in summertime, so (3) Eating ice cream must be abolished because it is killing people !!  Obviously this is absurd and a good example of the need for intelligent human reasoning.

In the same way, there is a need for intelligent human reasoning when it comes to GMO’s.  Isn’t it common sense that if you eat something that is genetically engineered to produce its own pesticide that it will continue to do so in your own gut?  Don’t you think it might be a good idea to test this prior to releasing to the public?

Isn’t it common sense that if you eat something that is genetically engineered to produce its own pesticide that it will continue to do so in your own gut?

The UCLA Food and Drug Allery Care Center also makes assertions based on the hygiene hypothesis, stating “The hygiene hypothesis states that excessive cleanliness interrupts the normal development of the immune system, and this change leads to an increase in allergies.”  This hypothesis is not unique to this institution.  There are many credible sources that state that as a society we are simply too clean.  By way of example, we are not doing ourselves any favors by washing with anti-bacterial soap (rather than normal soap) as it has been known to contain Triclosan, which is essentially a pesticide and believe to be carcinogenic.

The soap example is NOT referenced as trivia – this is instead an example of a common consumer item that can cause health problems because it contains unknown substances.  This relates to both the need to be clean, but not “too clean”, as well as the general public’s need to have access to food that does not have GMO’s.

As it has been in the past, and should continue to be in the future, food choice is a basic right of US Citizens.  Knowing the source of the food and having some information about its inputs is a big step in making informed, healthy food choices.  The FSMA will cripple small to medium sized farmers, which are arguably the best sources for local, organic, seasonal and unprocessed foods.

Repeal the FSMA

In its current form, the FSMA is not even close to being equitable (large producer vs. small-to-medium farmers) and it is not in the overall best interest of the US citizenry in terms of its stated goal to improve food safety, which is really part of a greater public good of overall health and well-being.

The FSMA should therefore be completely repealed and in its place should be legislation to support government-funded, yet independent research regarding the long-term effects of GMO and GMO food and food-like substances.  It should be a long-term study that runs in parallel with a complete moratorium on the proliferation of GMO within the US.

In absence of taking these two actions, (1) repealing the FSMA and (2) dealing with the potential ill health effects of GMO, the US government is essentially narrowing the choice of its citizens towards those food that are unproven in terms of the potential harm they can cause in a variety of ways including, but not limited to, cancer, allergies and food sensitivities.

This entry was posted in Eating Local, Food Consumption Choices, GMO, Health, Local Food and Government. Bookmark the permalink.

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