Tell the USDA: Actually, I prefer biodiversity

New “food safety” rule threatens small-to-midsize farms

Thanks to our friends at the National Organic Coalition (NOC) and National Sustainable Agriculture Coalition (NSAC) for sounding alerts about the new National Leafy Greens Marketing Agreement (NLGMA), an out-of-left-field rule that could close markets to small, sustainable producers of leafy greens. NOC says,

The proposal is mirrored on state marketing agreements already in place in California and Arizona, in which the conventional produce industry has been able to dictate farming practices that are in conflict with organic standards, are economically harmful to small scale and diversified farming operations, and have lead to destruction of wildlife habitat and other on-farm conservation measures.

Fortunately, it’s not too late. USDA is taking comments on this proposed rule until July 28th. Here is NOC’s recommended action:


USDA is seeking written comments from the public on the NLGMA proposal by July 28. Write USDA today to urge them to reject this proposal.

Go to and click on “Submit a Comment” on the right side.

Here are some suggested points to make:

  • I oppose the creation of a National Leafy Green Marketing Agreement, which I believe to be the wrong approach to address food safety concern
  • The Agricultural Marketing Service is not a food safety agency. It is bad public policy to create food safety regulations in order to address the “marketing” goal of increasing consumer confidence in the safety of leafy greens. Food safety policies should be driven by science, not by marketing problems.
  • The NLGMA, as proposed, would give the large conventional produce industry the ability to use its own world view to dictate farming practices. Small scale and organic farmers would have a very small voice in the standard-setting process.
  • The NLGMA is modeled on state food safety agreements in California and Arizona. In those examples, the conventional produce industry has pushed through food safety regulations that are biased against organic and small-scale farmers, have led to the destruction of wildlife habitat and discouraged good conservation practices on farms.
  • Diversified farming operations with complex rotations have been shown to be beneficial to the environment. Yet crop-by-crop food safety regulations, such as the NLGMA, are an economic disaster for diversified farming operations, and are biased toward large mono-cultural operations. For a farmer with 40 crops on 100 acres to comply with 40 different food safety regulations is prohibitively burdensome. Crop specific food safety regulations, such as NLGMA, will drive farmers out of environmentally sensitive diversified crop production, and toward chemical-intensive mono-cultural operations. This is counter to the goals of food safety and more environmentally sound agriculture.
  • The Food and Drug Administration is currently writing regulations to establish food safety standards for produce. Why is AMS proposing to establish standards that conflict with or duplicate the FDA standards, with the conventional leafy greens handlers in the drivers’ seat?
  • The NLGMA is a disaster waiting to happen, for farmers, consumers, the environment, and ultimately for food safety.

See the full NOC alert here.
See NSAC alert here.

Thanks for taking action for sustainable farming!