â€œThe vested interests â€“ if we explain the situation by their influence â€“ can only get the public to act as they wish by manipulating public opinion, by playing upon the public’s indifference, confusions, prejudices, pugnacities or fears. And the only way in which the power of the interests can be undermined and their maneuvers defeated is by bringing home to the public its indifference, the absurdity of its prejudices, or the hollowness of its fears; by showing that it is indifferent to dangers where real danger exists; frightened by dangers which are nonexistent.â€
— Sir Norman Angell (1872 â€“ 1967)
Vested interest groups have orchestrated a legislative lullaby to hush the public’s growing unease with the safety of its food supply. Their enablers in the mainstream corporate controlled media amplify a chorus of government officials and non-governmental organizations admonishing that the public must be confident that the food it buys is safe. But having confidence our food is safe is not the same as having food that is safe and wholesome to eat.
The American public has a great and unmet need to understand the true impacts (that is, the predictable consequences) of the Food Safety Enhancement Act of 2009, before the Senates passes its version of this dangerous bill. The US Congress has a long, tragic history of passing legislation that promotes the industrialization of our food supply, effectively implementing the wishes — both stated and unstated — of agribusiness, and it’s about to do it again.
Using the pretext of food safety, those behind the Food Safety Enhancement Act seek to institute changes the American public would not condone if it understood what is at stake. The country is being duped into believing that the pseudo-scientific measures prescribed by the bill will prevent new outbreaks of food-borne illnesses when in reality FSEA will usher in a number of undesirable outcomes, none of which do a thing to improve food safety. On the contrary, these measures will permit large processors to become an essentially unregulated segment of the industry by privatizing the inspection process, and — at the same time — the new regulations will constitute a cost-prohibitive barrier for small players to remain in business, making them easy targets for indiscriminant enforcement and greater market consolidation.
These proposed measures seek to apply â€œHACCPâ€ (pronounced â€˜hassip’) — a food protection approach originally designed to assure the safety of processed foods — to raw foods, a kind of mistake only a lawyer or lobbyist would see a reason to make. The food safety wrecking crew responsible for applying HACCP erroneously to â€œraw-in/raw-outâ€ meat and poultry operations in the 90s is back and ready to apply it erroneously to the produce market, the next FDA target in its quest for expanded oversight authority and police powers.
FSEA’s success would have severe consequences for the nationwide food localization movement. Though millions want to see the development of local food systems that provide an environmentally sound and health-sustaining alterative to the industrially manufactured products ruining our collective health, their dreams will be stamped out before they’re allowed to grow their infrastructure and reach due to the FDA’s expensive, unnecessary regulations.
If the Senate passes its version of HR 2749, we will also see our food laws brought significantly closer to harmonization with Codex Alimentarius, the cartel-acceptable food codes that the World Trade Organization employs to dictate to all member nations the terms of the global food trade for the benefit of transnational corporations.
An â€œAdaptiveâ€ Approach to Agriculture
Before we examine how FSEA will impact our food supply, it would be helpful to understand more about some highly relevant though little known history of American agriculture and its industrialization. Though industrialization is usually portrayed as something that happened as a natural result of technology bringing about ever-increasing efficiency, this notion doesn’t fit the facts.
With World War II, America saw its agricultural system intentionally subjected to political policies that radically transformed it. What was once a decentralized system that provided a means to self sufficiency and independence for tens of millions of farmers was purposefully centralized into a capital-intensive fossil-fuel dependent system that restructured local economies, permitting their wealth to be extracted by what are now transnational cartels dedicated to the so-called free market and globalized trade at all costs.
This transformation was the result of organized plans developed by a group of highly powerful â€“ though unelected â€“ financial and industrial executives who wanted to drastically change agricultural practices in the US to better serve their collective corporate financial agenda. This group, called the Committee for Economic Development, was officially established in 1942 as a sister organization to the Council on Foreign Relations. CED has influenced US domestic policies in much the same way that the CFR has influenced the nation’s foreign policies.
Composed of chief executive officers and chairmen from the federal reserve, the banking industry, private equity firms, insurance companies, railroads, information technology firms, publishing companies, pharmaceutical companies, the oil and automotive industries, meat packing companies, retailers and assisted by university economists â€“ representatives from every sector of the economy with the key exception of farmers themselves â€“ CED determined that the problem with American agriculture was that there were too many farmers. But the CED had a â€œsolutionâ€: millions of farmers would just have to be eliminated.
In a number of reports written over a few decades, CED recommended that farming â€œresourcesâ€ â€“ that is, farmers â€“ be reduced. In its 1945 report â€œAgriculture in an Expanding Economy,â€ CED complained that â€œthe excess of human resources engaged in agriculture is probably the most important single factor in the â€˜farm problem’â€ and describes how agricultural production can be better organized to fit to business needs. A report published in 1962 entitled â€œAn Adaptive Program for Agricultureâ€ is even more blunt in its objectives, leading Time Magazine to remark that CED had a plan for fixing the identified problem: â€œThe essential fact to be faced, argues CED, is that with present high levels farm productivity, more labor is involved in agriculture production that the market demands â€“ in short, there are too may farmers. To solve that problem, CED offers a program with three main prongs.â€
Some of the report’s authors would go on to work in government to implement CED’s policy recommendations. Over the next five years, the political and economic establishment ensured the reduction of â€œexcess human resources engaged in agricultureâ€ by two million, or by 1/3 of their previous number.
Their plan was so effective and so faithfully executed by its operatives in the US government that by 1974 the CED couldn’t help but congratulate itself in another agricultural report called â€œA New US Farm Policy for Changing World Food Needsâ€ for the efficiency of the tactics they employed to drive farmers from their land.
The human cost of CED’s plans were exacting and enormous.
CED’s plans resulted in widespread social upheaval throughout rural America, ripping apart the fabric of its society destroying its local economies. They also resulted in a massive migration to larger cities. The loss of a farm also means the loss of identity, and many farmers’ lives ended in suicide , not unlike farmers in India today who have been tricked into debt and desperation and can see no other way out.
CED members were influential in business, government, and agricultural colleges, and their outlook shaped both governmental policies and what farmers were taught. Farmers found themselves encouraged to give up on a farming system that employed minimal outsourced inputs and capital and get â€œefficientâ€ by adopting instead a system that required they go into debt in order to purchase ever more costly inputs, like fossil-fuel based fertilizers, chemicals, seeds, feed grain, and machinery. The local, decentralized food distribution networks that were previously in place became subject to corporate buyouts, vertical integration and consolidation, leaving farmers with fewer and fewer outlets to sell their goods. With this consolidation of grain handlers, railways, food processing, meat packing, brewing and beverage makers, cereal makers, food retailers and restaurants, more and more of the food dollar went to processors and retailers, which gained increased market power.
Farmers, meanwhile, were and continue to be squeezed on both ends: by input suppliers putting upward pressure on selling prices and by output buyers exerting downward pressure on their buying prices. This analysis is confirmed by the Keystone Center, an establishment think tank with representatives on its board from Monsanto, DuPont, Shell, Coca-Cola, Dow, General Electric and the Rockefeller Foundation, to name a few. The organization’s 2001 report â€œThe Keystone National Policy Dialogue on Trends in Agricultureâ€ observes that â€œAgricultural policy in many respects supported the concentration of farming into larger and fewer units. Some would say agricultural policy is biased toward bigness.â€ 
Echoing the plans laid out in CED reports, the Keystone report states that â€œAgricultural research programs have supported farm consolidation by focusing on substituting capital for labor, rather than developing knowledge and production systems that enable operators of modest-sized farms to enhance their incomes by using management and skills to minimize capital expenditures.â€  It was no accident that research programs at agricultural colleges favored one group at the expense of another.
The Keystone Report also clearly indicates that a focus on a less capital-intensive system would have been financially beneficial for smaller farmers, stating â€œHundreds of millions of public dollars have been invested in research to improve the efficiency of capital-intensive systems, while virtually nothing has been invested in low-cost systems. If this research imbalance were to be addressed, management-intensive systems might in many cases exceed the efficiency of capital-intensive systems. That would improve the competitiveness and income of moderately scaled, owner-operated farms, and counter the trend toward concentration. But this and other research approaches currently get relatively little attention in publicly funded research programs. Changing the research focus is a prerequisite to revitalizing small and medium-sized farms.â€
The current level of economic concentration we see today is the result of careful strategic planning. If actions are not taken to support a less-capital intensive methods a handful of global transnational corporations control will soon control the entire food supply. Farmers and livestock producers alike have been intentionally rendered price takers, while vested interests unfairly externalize environmental and production costs, capturing profits through monopolistic activities that should be halted through anti-trust enforcement by the US Department of Justice.
Get Big or Get Out!
Many people are much more aware of problems arising from industrially produced food thanks to Michael Pollan’s book The Omnivore’s Dilemma. In this work, Pollan asks a critically important question about why livestock were removed from pastures and stuffed into confined area feed lots: â€œWhy did we ever turn away from this free lunch in favor of a biologically ruinous meal based on corn? Why in the world did Americans take ruminants off the grass? And how could it come to pass that a fast-food burger produced from corn and fossil fuel actually cost less than a burger produced from grass and sunlight?â€
Though Pollan doesn’t directly answer that question, he does recognize that Earl Butz’s famous refrain of â€œGet big or get outâ€ had a lot to do with the answer. But Butz, we must now acknowledge, was only implementing CED policy recommendations.
Pollan did, however, correctly observe that â€œIn an industrial economy, the growing of grain supports the larger economy: the chemical and biotech industries, the oil industry, Detroit, pharmaceuticals (without which they couldn’t keep animals healthy in CAFOs), agribusiness, and the balance of trade. Growing corn helps drive the very industrial complex that drives it. No wonder the government subsidizes it so lavishly.â€ 
It is important that the American public understands that there has been a war waged against its own people, its farmers and their communities. And its people have been consistently losing that war as more segments of our food system have been put into the service of the military-industrial complex.
Agricultural Policies, Our Health Crisis, and Food Security
The same agricultural policies that made farmers into commodity crop growers are at the root of the current obesity epidemic. According to a report by the Institute for Agricultural and Trade Policy called â€œFood Without Thought: How US Farm Policy Contributes to Obesity,â€ â€œthe problem with the extensive use of cheap commodities in food products is that they fall into the very dietary categories that have been linked to obesity: added sugars and fats. US Farm policies driving down the price of these commodities made added sugars and fats some of the cheapest food substances to produce. High fructose corn syrup and hydrogenated vegetable oils â€“ products that did not even exist a few generations ago but are now hard to avoid â€“ have proliferated thanks to artificially cheap corn and soybeans.â€ In other words, US farm policies make poor eating habits an economically sensible choice â€“ with long-term negative health consequences for consumers and economically devastating consequences for family farmers.
More Americans are coming to understand the connections between their personal health, the economic heath of their communities and their long-term food security. Without a doubt, they know something has to change.
In response, people are setting up their own alternatives to the physically, environmentally and socially unhealthful industrial food system by developing an array of farm-to-consumer networks. The rapid increase in farmers’ markets, community-supported agriculture schemes, community gardens and home gardens reflect this growing understanding. People across the country are taking steps to shorten food miles and the food supply chain itself.
Their story is told in a video produced by Ruell Chappell, the founder of Springfield, Missouri’s Well-Fed Neighbor Alliance, that underscores why it is so important that communities, once self-sufficient, organize local sourcing for their food. In essence, the Well-Fed Neighbor Alliance, like countless other groups around the country, is striving to re-create what CED’s â€œAdaptiveâ€ Program for Agriculture destroyed.
Of course, the localization movement, though still in its early stages of development, hasn’t gone unnoticed by agribusiness, which recognizes that the movement directly competes with the highly consolidated retail chains for the consumer dollar.
The Return of Monsanto’s Public Policy Strategist to Government Service
While Michelle Obama’s organic White House garden is a testimony to the importance she places on safe fruits and vegetables in her family’s diet, her husband is ignoring the fact that our food supply is overflowing with FDA-approved unsafe, toxic chemicals pumped into it as pesticides, sweetners, colorings, preservatives and flavor enhancers. Rather than address these more far-reaching food safety issues that affect everyone’s long-term health, the Obama administration has made a far less pervasive problem its central food safety cause. And â€“ remarkably â€“ it named Michael Taylor Senior Advisor to the Commissioner at the Food and Drug Administration to oversee the implementation of new food safety measures.
Many people have expressed shock at this development, as Taylor, it can be argued, has done more than almost anyone in recent memory to undermine the safety of the food supply. He was instrumental in implementing biotech-pleasing policies that forced unlabeled genetically engineered food on an unwilling public. At the time Taylor bid the wishes of vested interests to get this product commercialized pronto, the government’s own scientists warned of the dangers GMOs could pose.
But Taylor ignored the public interest scientists’ objections, as well as the precautionary principle, insisting that his former client’s product was safe by virtue of a pseudo-scientific conceit of â€œsubstantial equivalence.â€ Almost two decades later, there’s now a tall pile of studies showing GMOs harm to public health, though these studies are routinely ignored by the corporate-owned media. The silence on the subject is such that many people still don’t know they routinely eat processed foods containing GMO ingredients and animals fattened on GMO fed.
In an earlier article I described how vested interests are behind the bumper crop of food safety bills we saw in Congress in the first part of 2009. I asserted that their unstated purpose is to harmonize US food safety laws with Codex Alimentarius, and identified Michael Taylor as their chief policy architect.
Taylor worked for a good part of the last decade in an assortment of establishment think tanks to develop a consensus among the food safety crowd for a set of policy changes that now underpin the 2009 food safety bills. HR 2749, the version the House rammed through, likewise contains the requirement that all food â€œfacilitiesâ€ employ a â€œscience-basedâ€ Hazard Analysis and Critical Control Point (HACCP) system to prevent human pathogen contamination at all stages from farm to table.
Will the Real HACCP Please Stand Up
Author and professor Marion Nestle is surprisingly enthusiastic about the return of Michael Taylor to government service. Given his troubling history, she admits her endorsement of him may sound like she’s been drinking Kool-Aid, but she nevertheless advises us to give him a chance. Specifically, Nestle credits Taylor with requiring that meat and poultry processors use â€œscience-basedâ€ HACCP plans. She also thinks it’s a fine idea to apply HACCP to all foods.
But not everyone shares Nestle’s enthusiasm about Taylor or about applying HACCP to all foods.
In fact, one of the world’s foremost experts on food safety, Dr. William H. Sperber, the microbiologist responsible for making the HACCP system a reality at Pillsbury in the early 70s, doesn’t think it’s so hot an idea. It was Sperber’s approach to food safety that the space program adopted so that its astronauts wouldn’t get sick from an onboard meal.
Prior to the development of HACCP, food manufacturers used quality control protocols relying on end-product testing. But these methods were proving inadequate to the task: testing small amounts of product simply cannot provide a high level of assurance that the entire product batch is free from contamination. To obtain a high assurance level that a large batch of product was safe, an enormous amount of end-product would have to be tested, a costly, wasteful and not necessarily useful tactic, as low level of contamination can escape detection. A better way was needed.
A real HACCP system does away with testing and instead builds food safety into the production process itself. In other words, food safety is assured by employing certain production methods that serve to kill certain identified pathogens that may be present during the production of the food.
Sperber, currently serving as Cargill’s Global Ambassador for Food Protection, writes in â€œHACCP and Transparency,â€ published in Food Control, that the policies implemented by Taylor, who he does not identify by name, are more legislation-based than science-based. The policies, according to Sperber, do not resemble a real HACCP approach and have been counterproductive to achieving food safety goals.
Sperber writes critically of the meat and poultry rules implemented by Taylor and considered the constant reference to them as â€œscience-basedâ€ to be, simply, a false claim. Sperber observes that â€œthe promulgation of opaque HACCP rules in the US was accompanied by another very counterproductive and troubling development â€“ the use of the term â€œscience-basedâ€ by the rule-making regulators and by their supporting legislators and activists. Any discussion of deficiencies in this HACCP rule was deflected by claims that the rule was science-based. More broadly today, appeals to â€œscienceâ€ are commonly used to discredit even the most constructive criticism of a food safety rule or policy. Any pathogen performance standard used in the context of the Pathogen Reduction/HACCP rule is not â€˜science-based.’ At best it is a very poor and inappropriate use of statistics.â€
Farm to Table HACCP â€“ NOT
As Sperber explain in another Food Control article entitled â€œHACCP does not work from Farm to Tableâ€: â€œIt is no accident that HACCP evolved at the food processing step of the Farm to Table supply chain. It is at this step that effective controls, such as cooking, drying, acidification, or refining are available to eliminate significant hazards”.Safety is assured by process control, not by finished product testing.â€
According to Sperber, the idea that HACCP can be applied from farm to table â€“ which is all the rage among those pushing for this legislation — is mistaken at best and deceitful at worst. He writes that â€œattempts to control these pathogens at the â€œFarmâ€ or the â€œTableâ€ ends of the supply chain have been disappointing because of the lack of effective control measures at these steps that are available at the food processing step.â€
The Misbranded HACCP a Repeated Failure
To see the results of this inappropriate use of HACCP, we can read â€œThe Jungle 2000: Is America’s Meat Fit To Eat?,â€ a report by Felicia Nestor and Wenonah Hauter that surveys United States Department of Agriculture’s Meat Inspectors. It concludes that â€œHACCP is not providing American consumers with the level of protection they expect and deserve from the purple USDA seal of approval. The USDA has allowed the meat industry to use HACCP as an industry honor system. Because of its enormous political power, the meat industry has had the clout to shape the HACCP program and make it a replacement for, rather an addition to continuous inspection of meat. Decreasing inspectors’ authority to inspect all along the line means processing lines can operate faster â€“ and that means more profits. Other changes in the law, such as removing the authority that meat inspectors had under the old system to require that facilities and equipment be kept clean, are also threatening food safety.â€
The authors stress the point that the HACCP program was being used to weaken meat inspection by reducing inspectors’ authority under the pretext of modern science. Under this false HACCP, inspectors could no longer examine the entire meat processing line, only those places that are industry-designated as critical control points.
Years before Sperber wrote in Food Control about the problems with Taylor’s brand of HACCP, the facts were making themselves obvious with continued outbreaks of food borne illness. Nestor and Hauter reported that â€œThe USDA made these changes under the guise of improving meat inspection, and they are shrouded in jargon about science-driven, risk-based food safety. The agency could have maintained continuous inspection, while adding microbial testing and other science-based tools, thus increasing needed protections. Instead the USDA, an agency that is overly responsive to agribusiness concerns, has betrayed consumer trust by facilitating the partial dismantling of the meat inspection system.â€
One meat inspectors surveyed stated that â€œwe’ve had more recalls since HACCP was implemented than I can ever remember. This should tell everyone that the inspection in the plants is not what is used to be, and I think HACCP is to blame.â€
Another meat inspector complained that â€œ[HACCP] replaced FSIS’ long-standing program of meat and poultry inspection. Under the pre-HACCP system, the production of meat and poultry products was monitored at every stage by Government employees rather than in-plant production managers. The HACCP program reversed this arrangement by allowing a plant to monitor the safety of meat and poultry products.â€
This is not the same HACCP that took American astronauts to the moon. As an insightful inspector observed, â€˜HACCP has very good results when used in the way it was designed for â€“ ready-to-eat product. HACCP doesn’t fit into the production realm of raw product. Product comes in raw [and] goes out raw.â€
HACCP Used As a Tool for Privatizing the Inspection Process
Instituting HACCP to the raw meat and poultry industries served to de-regulate it for the big players and hyper-regulate it for the smaller players. Large corporations with financial reserves and persuasive legal staff privatized the food safety function. With inspectors confined to â€œcritical control points,â€ plants were free to increase the speed of their disassembly lines, a profitable practice that unfortunately encourages a lot more feces, pus and other not insignificant unmentionables to ride down the line and out the door, stamped with a purple seal of approval.
While the fake HACCP program made it easier for the large players to gross more and cover up contamination with chemical sprays and irradiation, small players found it substantially more expensive and difficult to conduct business. In its important and informative report â€œWhere’s the Local Beef?: Rebuilding Small-Scale Meat Processing Infrastructureâ€ Food & Water Watch recommends that the USDA fix the â€œoverarching problems in its inspection programs, including an overemphasis on meat inspectors examining company food safety plans instead of inspecting product.â€ Food & Water Watch had examined the effects of HACCP on small meat slaughter and processing operations and found that the complexities of one-size-fits-all federal regulations was a key reason for business closings.
It’s also noted in â€œWhere’s the Local Beef?â€ that â€œwhen USDA adopted [HACCP], all federally and state-inspected plants, regardless of their size, were required to, as well. Now these plants have to justify their plans with scientific studies and tests. They also have to set up extensive self-monitoring and recordkeeping systems. Because smaller plans often make a greater number of more complex products (such as sausages), they require multiple HACCP plans that also are more extensive.â€ Possibly because they have no leverage when they inspect large processors, agency inspectors â€œexert more oversight and enforcement action at the smaller grinders and explicitly makes them responsible for changing the food safety practices at the largest plants, which are suppliers of raw material for the small plants.â€ The seal stamped in purple ink on the carcass doesn’t mean much anymore.
You Don’t Know What You’ve Got â€˜Til It’s Gone”
So, just when the country is awaking to the need to relocalize its food sources, we find that many meat processors who would serve this growing market have been forced out of business by vague, onerous and costly regulations imposed under the guise of food safety.
Do we want the same thing to happen to our produce growers? Do we want to hyper-regulate those farmers whose practices do not contribute to the food poisoning problems endemic to industrially produced food products and de-regulate those whose practices poison us? No? But that’s what we’re being set up for with the Food Safety Enhancement Act of 2009.
DÃ©jÃ Vu All Over Again
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 â€œfacilities,â€ 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 â€œperformance standards,â€ whatever those are determined to be, the food â€œgrown, harvested, processed, packed, sorted, transported, or held under conditions that do not meet the standards,â€ would be considered adulterated (Sec. 104 (a)). So, even if a farm’s or â€œfacility’sâ€ 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.
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. 
One of the few organization that is able to see the unnecessary hardships this bill would place on farmers is the Farm-to-Consumer Legal Defense Fund issues, which notes that the cost of implementing these proposed regulation would drive many farmers off their land and lead to further consolidation of the industry.
Is this perversion of HACCP due to an innocent misunderstanding, lack of industry experience or incompetence? Or, is there something else going on?
If you follow some of Taylor’s activities since he ceased (officially) serving as Monsanto’s Vice President of Public Policy and the present time, you’ll find that he’s worked for no less than five think tanks, churning out policy recommendation and reports to support his vision of a global food system. He’s also picked up an academic affiliation, becoming a research professor at the George Washington University School of Public Health and Health Services.
As Director of the Global Food Systems Program at the Resources for the Future, a highly influential establishment think tank, Taylor has steadily worked on projects that promoted certain policy recommendations for new food safety regulations, but it is acknowledged that food safety is merely one part of his larger concern. 
In a short 2002 report published RFF called â€œReforming Food Safety: A Model for the Futureâ€ Taylor writes that â€œWe operate within a global food system in which World Trade Organization (WTO) agreements have an important impact on the standards that govern both food imports and exports. To achieve its legitimate public health and economic objectives within this system, the United States must be an international food safety leader.â€ 
To further his plan to make the US an international food safety leader, Taylor wants a pass a â€œlaw that includes a mandate and authority to pursue systematic prevention of foodborne disease from the farm to the table through HACCP-based process control or other preventive strategies. The law should make HACCP mandatory for all processing operations, unless exempt”â€ 
In testimony he gave on July 29, 2009, before the Subcommittee of Domestic Policy Committee on Oversight and Government Reform, Michael Taylor told those assembled that â€œthe FDA is leading an effort through the Codex Alimentarius Commission, the international food safety standards body, with support of the Food and Agriculture Organization/World Health Organization, to develop commodity-specific annexes to the Codex hygienic code for fresh fruit and vegetable production, starting with an annex for fresh leafy vegetables and herbs. In June 2009, FDA conducted the first Codex international electronic working group with members of the Codex Committee on Food Hygiene (CCFH) to advance the draft Annex for Fresh Leafy Vegetables to the next stage of completion. In November 2009, CCFH will consider how to proceed with the next tier of priority commodities.â€ 
What this means is that the Draft Guidance for fresh leafy vegetables recently released for comment by the FDA is already being integrated into Codex guidelines. The FDA is only required to given the public an opportunity to provide comments to the proposed regulations; the public shouldn’t be under the impression that its input matters to the FDA or will be incorporated into FDA regulations.
But according to Dr. Sperber, the Codex Alimentariius Commission is not the appropriate international agency to oversee food safety, because Codex doesn’t do anything to assure food is safe; rather, Codex issues guidelines used for trade-compliance purposes by the World Trade Organization. Sperber says boots-on-the-ground inspectors are needed and recommends the creation of a new international agency â€“ a Food Protection Organization — along the lines of the WHO or FAO that would be responsible for food protection issues.
If it were only so easy: These organizations’ missions were hijacked long ago by financial and corporate interests and don’t really serve their stated, usually somewhat noble-sounding, purpose. The same multinational corporations that control our federal regulatory agencies likewise own and operate the supranational organizations. While harmonizing US laws with Codex might not improve food safety, Taylor is undoubtedly aware it will do much to advance global governance.
And, with the advancement of global governance, sustainable agriculture, wholesome food and health freedom will go the way of the buffalo and the American Indian.
Don’t Get Fooled Again
We might want to stop letting lawyers establish policies that are better made by scientists with actual professional experience and without certain financial entanglements that call their scientific independence into question. As Sperber has observed, one of the barriers to effective food protection is the absence of food industry expertise in top government positions. Instead, those key jobs are filled by lawyers and former lobbyists.
FSEA 2009 is scientifically unsupportable and will not make the food supply any safer.
It’s a con job.
Don’t fall for it.
And don’t let your Senators fall for it, either.
 A.V. Krebs, The Corporate Reapers: The Book of Agribusiness. Essential Books, Washington DC, 1992, pp 289-299.
 Agriculture in an Expanding Economy: A Statement by the Research Committee of the Committee for Economic Development, 1945. Republished by AstroLogos Books, New York. www.AstroLogos.org (Books on Demand)
[3} An Adaptive Program for Agriculture: A Statement on National Policy by the Research and Policy Committee of the Committee for Economic Development. The Committee for Economic Development. July 1962. http://www.normeconomics.org/adaptive.html
 â€œA Farewell to Farms,â€ Time Magazine. July 20, 1962. http://www.time.com/time/magazine/article/0,9171,896357,00.html
 â€œReorienting Agricultural Research Back to the Farmâ€ by E. Ann Clark, Crop Science, University of Guelph, Ontario Canada. Presented at Practical Partnerships. A New England Sustainable Agricultural Conference, November 1997, Portland, Maine. http://www.plant.uoguelph.ca/research/homepages/eclark/maine.htm
 Joel Dyer, Harvest of Rage: Why Oklahoma City Is Only the Beginning, Westview Press, 1998.
 Vandana Shiva, â€œFrom Seeds of Suicide to Seeds of Hope: Why Are Indian Farmers Committing Suicide and How Can We Stop This? April 28, 2009
 â€œThe Keystone National Policy Dialogue on Trends in Agriculture: Summary of Deliberationsâ€ The Keystone Center, March 2001, p. 35.
 â€œThe Keystone National Policy Dialogue on Trends in Agriculture: Summary of Deliberationsâ€ The Keystone Center, March 2001, p. 35.
 â€œThe Keystone National Policy Dialogue on Trends in Agriculture: Summary of Deliberationsâ€ The Keystone Center, March 2001, p. 40.
 Michael Pollan, The Omnivore’s Dilemma, The Penguin Press, 2006, page 199.
 Michael Pollan, The Omnivore’s Dilemma, The Penguin Press, 2006, page 201.
 â€œFood Without Thought: How US Farm Policy Contributes to Obesityâ€ by Heather Schoonover and Mark Muller, Institute for Agriculture and Trade Policy, March 2006.
 â€œLocal Food = Jobs = Securityâ€ a video by Ruell Chappell and the Well-Fed Neighbor Alliance
 Health Risks of GMO Foods: Summary and Debate. Institute for Responsible Technology. http://www.responsibletechnology.org/Public/GeneticRoulette/HealthRisksofGMFoodsSummaryDebate/index.cfm
 Nicole Johnson, â€œ2009 Food â€˜Safety’ Bills Harmonize Agricultural Practices in Service of Corporate Global Governanceâ€ OpEdNews, April 20, 2009.
 Marion Nestle’s blog Food Politics â€œMichael Taylor appointed to FDA: A good choice!â€ July 7, 2009.
 William Sperber, â€œHACCP and Transparencyâ€ published by Food Control, Vol. 16 Issue 6, July 2005, pp 505-509
 William Sperber, â€œHACCP and Transparencyâ€ published by Food Control, Vol. 16 Issue 6, July 2005, pp 507-508.
 William Sperber, â€œHACCP Does Not Work From Farm to Tableâ€ published by Food Control, Vol. 16, Issue 6, July 2005, p 512.
 William Sperber, â€œHACCP Does Not Work From Farm to Tableâ€ published by Food Control, Vol 16, Issue 6, July 2005, p 512.
 â€œThe Jungle 2000: Is America’s Meat Fit To Eat?â€ by Felicia Nestor, Government Accountability Project, and Wenonah Hauter, Public Citizen. A Survey of the United States Department of Agriculture’s Meat Inspectors. September 2000. p. 7.
 â€œThe Jungle 2000: Is America’s Meat Fit To Eat?â€ by Felicia Nestor, Government Accountability Project, and Wenonah Hauter, Public Citizen. A Survey of the United States Department of Agriculture’s Meat Inspectors. September 2000. p. 8.
 â€œThe Jungle 2000: Is America’s Meat Fit To Eat?â€ by Felicia Nestor, Government Accountability Project, and Wenonah Hauter, Public Citizen. A Survey of the United States Department of Agriculture’s Meat Inspectors. September 2000. p. 45.
 â€œThe Jungle 2000: Is America’s Meat Fit To Eat?â€ by Felicia Nestor, Government Accountability Project, and Wenonah Hauter, Public Citizen. A Survey of the United States Department of Agriculture’s Meat Inspectors. September 2000. p. 46.
 â€œThe Jungle 2000: Is America’s Meat Fit To Eat?â€ by Felicia Nestor, Government Accountability Project, and Wenonah Hauter, Public Citizen. A Survey of the United States Department of Agriculture’s Meat Inspectors. September 2000. p. 48.
 â€œWhere’s the Local Beef?: Rebuilding Small-Scale Meat Processing Infrastructureâ€ by Food & Water Watch, June 2009, Executive Summary.
 â€œWhere’s the Local Beef?: Rebuilding Small-Scale Meat Processing Infrastructureâ€ by Food & Water Watch, June 2009, page 6.
 â€œWhere’s the Local Beef?: Rebuilding Small-Scale Meat Processing Infrastructureâ€ by Food & Water Watch, June 2009, page 7.
 â€œSmall Farmer Warns â€˜HR2749 Will Put Me Out of Business’â€ by Kimberly Hartke, July 24, 2009. http://www.kartkeisonline.com
 Helen Coster, â€œDo you Know Where That Berry Came From?â€ The Silver Lining in food poisoning: Somebody can make a living relieving consumers’ fears.â€ Forbes Magazine, May 11, 2009.
 Farm-to-Consumer Legal Defense Fund
 â€œSetting Food Safety Priorities: Toward a Risk-Based Systemâ€ Transcript of Proceedings. RFF Conference Center, May 23-24, 2001. page 2.
 Michael Taylor, â€œReforming Food Safety: A Model for the Futureâ€ Resources for the Future, February 2002, Issue Brief 02-02, p. 2.
 Michael Taylor, â€œReforming for Safety: A Model for the Futureâ€ Resources for the Future, February 2002, p. 9-10.
 Testimony of Michael R. Taylor, JD, Senior Advisor to the Commissioner, Food and Drug Administration, Department of Health and Human Services before Subcommittee of Domestic Policy Committee on Oversight and Government Reform, US House of Representatives, July 29, 2009, p. 8.
 William Sperber, Video of â€œGlobal Food Protection: A New Organization Is Neededâ€ presented at Food Import Safety Conference, University of Wisconsin, Madison: http://mediasite.engr.wisc.edu/Mediasite/Viewer/?peid=a3f4fe4f0b75482f9f7ec0cd68ff3462
 â€œCargill Executive Cites Single Regulatory Agency as Necessaryâ€ The Food Safety Consortium Newsletter, Vol. 19, No. 3, Summer 2009.
Author’s Bio: Nicole Johnson is a researcher and activist living in Ventura county, California. Her kids wish she would go back to painting and stop worrying so much about the world.