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September News

For those of you who are not CSA members, it has been a long time since I have checked in. Perhaps I just get busier every year, or perhaps at 60, I just can’t work as hard and fast! As I have heard was the case for a lot of farmers and gardeners this year, the season from an annual vegetable standpoint was miserably tough for the months of June and July. Somewhere around the last third of August, things started to pick up for us here, with a return to what I have lately remembered to be sexy looking crops of high quality. But in the interim there were a lot of victims – potatoes, garlic, early brassicas and summer squash, winter squash, green beans – ay! Humbled again, I thought long and hard about what I could have done better. I have found a lot of “answers” in a book titled “The Intelligent Gardener” by Steve Solomon. He is a curmudgeon who “grew up” on J. I. Rodale (as I did) and has taken his medicine a few times over for not being as scientific as he is now about the art of gardening. Mineral balancing is key – okay, I have been studying and practicing that for a few years now. But he brought a whole new understanding to me with his explanation of native soils and rainfall and how they impact plant growth – particularly annual vegetable crops which are rather petulant in their desire for lots of fertility, and their shallowness (of root in this case). Be sure to get the book, but if you don’t get around to reading it, I can tell you that besides doing all the great things that J. I. Rodale and William Albrecht suggest, organic matter and mineral balancing respectively, I will be bringing just the right (hopefully) amount of nitrogen from outside sources into my planting scheme in the springtime. And, we are going to cut our vegetable growing area into a little under one half of this year’s 2+ acres next year. And everything will be mulched that can be mulched – either with black plastic (a handful of crops – I really hate the stuff) or my favorite – hay. That is the wisdom that can only come from age for us slow learners.
 
Meanwhile, as is the case elsewhere, our perennial plantings scored at the top of the charts this year – except the grapes which were fantastic last year. We all gained weight over the past three weeks on the hundreds of pounds of peaches that we picked, sold and processed. We are selling frozen peaches (all cut up and bagged) at $4/lb. Enquire. Now we are on to apples. Our greatest harvest over the past 30 years has totaled about 2 bushels. This year we have more than 10 bearing trees, all of them full, and applesauce preparation is the order of the day every morning from 7 – 7:15. Let us know if you would like to buy some from us – they aren’t anything to write home about physically, but tasty eating out of hand and also good for sauce or cider – and of course certified organic. They will be $1.50/lb on the hoof.
 
Plums were fantastic; the red raspberries – Latham summer bearers – were more prolific than I have ever experienced.  And blueberries too. After Jack and I sort out the wine needs, I may be selling frozen blueberries and red raspberries at $5/lb. Let us know if you are interested. Our rhubarb started the season looking mighty fine and highly productive. The shocker with that is that we are still harvesting thick stalks. Normally it starts to mush up around June 15. It may be in part due to the comfrey which has moved in next door. See my article on comfrey below – my latest wonder herb.
 
Jack broke his femur on July 8 – 2 months ago, falling off a ladder trying to thin that last peach branch on the last tree. We are both happy that he is well healed now – moved from walker through crutches, and just barely using a cane. For the love of peaches! I have been doing an extra share of heavy lifting, but soon hope to start sharing more of that with him as the fall proceeds.
 
Our pigs went off to meet their fate today. They were well behaved about it, and happy to be sent off with a few apples to munch that I shoved through the bars of the trailer as they left. We have a fair amount of pork unsold at this juncture, so please feel free to pre-order for September 27 pick up, or come by after that date to buy out of the freezer. All of our meat is explained more thoroughly at www.mhof.net/meat. This batch of pigs spent their entire lives with us in the woods. They stopped by for whey and organic hog grain every day to supplement the wonderful things that pigs find in the woods. There are very few certified organic pigs around, and we are happy to state that ours are.
 
We have about 100 meat birds unspoken for that will be ready on Sunday, October 20. Also certified organic, they eat top of the line Nature’s Best broiler crumbles, but more importantly move to fresh grass daily, eat sprouted grains of oats, wheat and barley laced with kelp meal, and comfrey. You won’t find a tastier bird.
 
We don’t have that many turkeys left for Thanksgiving as we are selling 60 of the 100 wholesale. If you want one, best to order now. The beef is sold out.
 
We have lots of fantastic eggs at $6/dozen if you are local and want to set up a regular visit, or if you aren’t so local but want to place an order with friends for cooperative purchases. As with all of our birds, our layers get top of the line treatment and it shows in the quality of the eggs.
 
It is nice to be in touch again. I hope you are doing well, and as we, are appreciative that we are surrounded by such good food in a world where so many go hungry and so many are eating low quality food and are not even aware of it. I ask you to read the following long article that Jack wrote about the Food Safety Modernization Act and take action. And enjoy my piece on comfrey that I wrote for the NOFA/Mass Newsletter.
 
Julie    
julie@mhof.net; 978-355-2853

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Comfrey
Julie Rawson
 
When we moved to our land in 1980 I immediately bought a few comfrey plants, as I had read in my “pre-returning to the land” period – that wonderful time when one has plenty of time to read before actually being out there slogging every day – that comfrey was a miracle plant. And then, for the better part of 30 years I just let it grow and multiply. Every once in awhile I would cut some and feed it to the chickens, but there was, sometime in that span of years, a comfrey scare, that it was somehow bad for you. The culprit, it seems, is the pyrrolizidine alkaloids that ingested in extremely large doses over an extended period of time can cause liver damage. While researching for this article I cam upon one reference from a Dr. James Duke that suggested that the amount of these harmful alkaloids in 1 bottle of beer is equal to about 100 cups of comfrey tea. Perhaps that can put this all in perspective.
 
It was Harvery Ussery – www.themodernhomestead.us, at the NOFA/Mass Advanced Growers Seminar 2 or 3 years ago who reminded me of the amazing versatility and value of this plant that has served intelligent people of the land for centuries. Also known as bruisewort, knitback, knitbone, boneset, slippery root, bruisewort, ass ear, and blackwort, comfrey contains ample quantities of Tannins, Rosmarinic acid, Allantoin – which encourages the rapid growth of cells, Steroidal saponins, Mucilage, Inulin, Gum, Carotene, Glycosides, Sugars, Beta-sitoserol, Triterpinoids, Vitamin B 12, A, C, silicon, calcium, potassium phosphorous, iron, iodine, zinc and other traces.
 
It is claimed to contain 22-31% protein and to have produced 140 tons of biomass per acre in the world record. It is the greatest producer of vegetable protein and fastest protein-builder on earth. Acre for acre it produces 20 times more protein than soybeans. Since the 80s it has been suppressed in the US, but is grown throughout the rest of the world for animal feed, from ruminants to single stomach large animals, poultry, and earthworms.
 
It is the queen of multi-functional plants, and it spreads by root division – it will spread very rapidly and hard to get rid of. Sheet mulch out if necessary or build a hot compost pile on top of it. It is a beneficial insect attractor, wound healer; enormous root system and dynamic mineral accumulator and delivers these minerals to its leaves which are then available for our use. It is a biomass accumulator; you can grow for a mulch plant; Chickens love comfrey; it feeds the soil more than anything else; it creates a lot of sloughing material into the soil all the time; there will be lots of earthworms around it. It is used to rebuild tissue, muscle, tendons and bones. Comfrey proliferates cell division and cell growth. One resource person uses comfrey in his salads in the early spring.
 
So enough background. Our comfrey started to escape into our rhubarb. I started to get into the habit of yanking a plant (as much as I could get) of comfrey each day to feed to the baby meat birds and turkeys this summer. I quickly was able to make a few interesting observations. The baby birds flocked to it and ate it ravenously – chose it over their bagged, organic feed, their daily dirt ration, and the sprouted grains. So I brought more. And then their infant health sky-rocketed. To date – 6 weeks later, we have lost 2 of our 250 meat birds and 1 of our 100 turkeys (our best record ever). They are fat and sassy and very active – pictures of poultry health. They are now out on pasture, and we are now harvesting armfuls of comfrey every day and delivering it to them – and also to the laying hens who are laying like gangbusters. And the comfrey is cranking along – still trying to take over the rhubarb, and proliferating in all the grassy edges of the farm. We also moved it under our fruit trees after the Harvey event, and have a nice stand of it all over in the orchard.
 
After doing today’s research I have determined to use comfrey yet more on the farm, for mulch for starters, and perhaps start branching out and feeding it to the cows and pigs. We are now drinking comfrey tea every day, and for two years we have been making a nice comfrey salve that we use liberally around here and also sell. As is often the case, it seems that the best things in life are free!
 
Many Hands Comfrey Salve recipe
1 quart olive oil
2 cups dried comfrey leaf
4 oz beeswax- by weight
25 drops lavender oil
4 Vitamin E capsules
 
Combine olive oil and comfrey leaf and heat at a very low temperature (we put it on the far right of the woodstove overnight)
 
Strain the comfrey out of the oil. Combine the infused olive oil and beeswax and heat slowly until beeswax melts.
 
Remove from heat, add lavender oil and Vitamin E.
 
Some of my internet resources that helped me put together this article.
Rose Mountain Herbs
Coe’s Comfrey
Permies.com


Proposed Food Safety Regs Stir Farmer Anger, Especially on Water and Manure
by Jack Kittredge
 
The US Food and Drug Administration (FDA) has begun “listening sessions” around the country about its proposed food safety regulations to implement the Food Safety Modernization Act (FSMA). The FDA has estimated that it could cost small farms up to $13,000 annually to comply with the new regs, and the officials in attendance at these hearings have gotten quite an earful.
 
On August 19, in Augusta Maine, farmers told state and federal officials that: “You’re gonna be putting farms out of business” despite no evidence that food safety problems have surfaced on small operations. In New Hampshire, on August 20, about 300 farmers and others attended a similar session in Hanover to voice their concerns.
 
Although roughly 60 percent of US farms (110,000 out of 190,000) would be exempt from the regs because of the $500,000 gross farm income exemption in the law, many farms were concerned that the exemptions are not guaranteed and could be taken away by any FDA official on the grounds that

  • the farm engages in some value-added production,
  • that gross farm income may exceed the threshold when all farm activities are added together, or
  • that an outbreak of microbial contamination has been  detected on the farm.

 
On August 22, in Hadley, MA, Peg and John Morse of the Big Apple Farm in Wrentham, MA testified that, since they irrigate from three ponds and two wells, they thought the water testing requirements alone of the new regs could end up costing them an additional $20,000 per year.
 
The Summer 2013 issue of The Natural Farmer brought most NOFA members up to speed on these complex proposed regs, but several developments since that issue need to be noted.  First, the comment period has been extended to November 15, 2013, to give farmers and consumers more time to read, understand, and comment on the regs. Second, the FDA initially decided that these regs, despite their widespread impact on agricultural land and practices throughout the country, did not require an environmental impact statement (EIS). They have since reversed themselves and are now preparing an EIS. There is no clarity on what will happen should the environmental assessment require changes in the regs – will a new proposed rule be issued or not? But the assumption has to be that the rules currently proposed may be binding and we need to respond to them.
 
Lastly, although there are significant health issues with pesticide and other farm chemical use, including GMOs and glyphosate, these are specifically excluded from FSMA consideration. The Act applies only to microbial contamination.
 
The rest of this article will focus on the most controversial two provisions – the water and the manure regulations. (You can get more information on these two, as well as other provisions of the FSMA at: http://sustainableagriculture.net/fsma/.
 
Agricultural Water
 
FDA considers water to be “agricultural water” if it is intended to or likely to contact produce or food-contact surfaces.  Examples of agricultural water include irrigation water that is directly applied to the harvestable portion of a crop, water used for preparing crop sprays, and water used for washing or cooling harvested produce.
 
Because the methods for detecting microbial pathogens in water are so limited, FDA is basing its proposed standards on monitoring for hazards and testing water for fecal contamination – specifically for generic E. coli, which FDA claims is a satisfactory indicator for determining fecal contamination.
 
General Water Quality Requirements

Generally, the proposed agricultural water standards require farmers to ensure that agricultural water is “safe” and “of adequate sanitary quality for its intended use.”  This general requirement underpins the entire water standard.
 
If, through any of the scenarios discussed below, a farmer has determined or has reason to believe that the agricultural water is not safe or of adequate sanitary quality, generally the standards require the farmer to immediately discontinue use of that water on the farm.  The farmer must then take action to address the water quality problem in one of two ways:

  1. Inspect the on-farm agricultural water system components that are under the farm’s control, identify any conditions that could be causing the problem, make any necessary changes to fix the problem, and retest the water to ensure the changes were effective; or
  2. Treat the water (see the water treatment section below).

Water System Inspection Requirements

The proposed standards require a farmer to inspect his/her agricultural water system at the beginning of a growing season.  In that inspection, a farmer must identify conditions that may result in hazards contaminating produce through water, and take into consideration:

  • The nature of each agricultural water source (e.g., ground water or surface water);
  • The extent of the farmer’s control over each source;
  • The degree of protection of each source;
  • Use of adjacent or nearby land; and
  • The likelihood of hazards being introduced in the water by a farm upstream.

Water Treatment Requirements

If the water is not safe due to conditions beyond a farmer’s control, and therefore the farmer has to treat the water according to the proposed rule, then FDA suggests treating water with an antimicrobial compound.  FDA notes, however, that any chemical used to treat water would need to be registered with the Environmental Protection Agency and that, presently, there is no such registration for chemical treatment of irrigation water.  FDA assumes that this issue will be addressed and a new registered product created before farmers must comply with the water standards (see compliance information below).
 
Water Testing Requirements

A farmer would not be required to test his/her agricultural water if he/she:

  • Uses water from public water systems and has public water system results or certificates of compliance; or
  • Treats the water according to the water treatment requirements (see above).

 
For farmers that have to test water, FDA is proposing two numerical standards for testing:

  1. No detectible E. coli present per 100 ml of water:  This standard would apply to water used for an activity during and after harvest, water used to make agricultural teas, and water used in sprout irrigation.
  2. No more than 235 colony forming units (CFUs) generic E. coli per 100 ml for a single water sample, and a rolling geometric mean of five samples of no more than 126 CFU per 100 ml:  This standard would apply to water used for growing activities (except for sprouts) that directly contact the harvestable portion of the crop.  FDA is also allowing farmers to offer an alternative to this standard (see below).

 
To determine whether agricultural water meets the above standards, FDA is proposing testing frequencies based on the type of agricultural water used.  The most stringent testing frequencies apply to untreated surface water:

  • If the untreated surface water is from a source where a “significant quantity of runoff” is likely to drain into it (e.g., a river or lake), then a farmer must test the water at least every seven days during the growing season.
  • If the untreated surface water is from a source where underground aquifer water is transferred to a surface water containment in a way that minimizes runoff drainage into the containment (e.g., on-farm constructed water reservoir), then a farmer must test the water at least once each month during the growing season.

 
For other water sources, such as ground water, FDA is proposing that farmers test at the beginning of each growing season, and every three months thereafter during the growing season.
 
FDA is allowing farmers to use alternatives to requirements for testing water and taking action based on those tests when agricultural water is used during growing of covered produce (other than sprouts).  Farmers are expected to provide documentation showing that the alternative method is supported by adequate scientific data indicating that the alternative would provide the same level of public health protection and would not result in adulterated produce.  This alternatives option is not applicable to water used during and after harvest, water used to make agricultural teas, and water used in sprout irrigation.
 
Compliance Dates

Because the agricultural water standard is based on limited scientific evidence, because there are huge research gaps in agricultural water issues, and because the proposed standards are untenable at this time, FDA is proposing extended compliance dates for the agricultural water standards.
 
For the water testing, monitoring, and associated recordkeeping requirements, FDA is proposing the following compliance dates from the time that the final Produce Rule goes into effect:

  • Six years for very small businesses,
  • Five years for small businesses, and
  • Four years for all other farms.

 
FDA Needs to Hear from YOU About Agricultural Water:

If you use agricultural water, FDA needs to hear from you about how these proposed rules might impact your farm operation.  See below for how to comment.
 
Manure and Compost
 
Farmers use soil amendments such as manure and compost to improve soil fertility and soil quality, and to enhance populations of beneficial microorganisms in the soil.  Sustainable and organic producers in particular rely on manure and compost instead of synthetic chemicals to add fertility to their fields.
 
The Food Safety Modernization Act (FSMA) requires the Food and Drug Administration (FDA) to develop regulations aimed at improving the safety of produce.  Soil amendments such as manure have been identified as a potential vector for pathogens that may contaminate produce, and Congress required FDA to include standards for “soil amendments” when developing new regulations.  In the proposed Produce Rule, FDA has developed standards directed to “biological soil amendments of animal origin” – e.g., manure and compost that includes animal waste and human waste.
 
In addition to requiring standards on soil amendments, Congress also specified that FDA could not propose requirements that conflict with or duplicate the requirements for certified organic production.  Manure and compost are critical soil amendments in certified organic production and in sustainable farming systems, and it is important that new standards work for these types of systems.  Congress also required FDA to take into consideration conservation and environmental practice standards such as those by USDA’s Natural Resources Conservation Service, which offers assistance with nutrient management and composting facilities, among other things.
 
Proposed Standards Directed to Manure and Compost

The requirements only apply to biological soil amendments of animal origin – including manure, bloodmeal, and fish emulsion – and human waste.  They also address agricultural tea (“compost tea”).  They do no apply to non-biological soil amendments (e.g., physical or chemical) and they do not apply to soil amendments of non-animal origin such as yard waste, purely vegetative matter, or shrub trimmings.
 
Broadly, the proposed standards seek to avoid contamination of “covered” produce by pathogens potentially present in biological soil amendments of animal origin.  Generally, the proposed standards set treatment requirements for soil amendments and minimum intervals between application and harvest.
 
A 45-day interval is required if the amendment has been applied in a manner that minimizes the potential for contact with covered produce during or after application, and if the amendment has undergone a scientifically valid controlled composting process that satisfies the microbial standard for Salmonella and fecal coliforms
 
This 45-day interval is in conflict with the National Organic Program (NOP) regulations, which do not require an interval between application and harvest for manure treated by a composting process that is consistent with NOP composting standards.
 
For situations that would require the 45-day interval, FDA will accept “alternative” methods if they are scientifically valid, controlled composting processes supported by adequate scientific information or data.
 
In the case of agricultural tea, the water used must meet the requirements of the water standards.

FDA considers a soil amendment to be untreated if it has not been processed by a scientifically valid treatment method, has been contaminated after treatment, has been recombined with an untreated amendment, or is contaminated with a hazard.  FDA considers agricultural tea to be untreated if it contains an agricultural tea additive.
 
FDA is proposing to require a nine-month interval between application and harvest if the soil amendment is untreated and there is chance that the amendment will come into contact with covered produce after application.
 
This nine-month interval is in direct conflict with the National Organic Program regulations, which require a three or four-month application interval for untreated manure depending on whether the edible portion of the crop comes into contact with the soil indirectly or directly, respectively.  This proposed requirement and the 45-day interval in compost (see above) are also in direct conflict with FSMA, which requires standards not to conflict with NOP regulations. 
 
Additional Requirements

FDA does not allow the use of human waste for growing covered produce, except for sewage sludge biosolids that are used according to Environmental Protection Agency requirements.
 
To accompany these proposed standards, FDA lays out specific recordkeeping requirements 
 
What the Proposed Standards Do Not Require

The proposed standards for biological soil amendments of animal origin do not apply to soil amendments of purely non-animal origin.  Additionally, the requirements do not apply to physical or chemical soil amendments, such as synthetic fertilizers.
 
These standards do not apply to animal feces deposited in a field by wild or domesticated animals. Separate standards apply in that instance.
 
FDA Needs to Hear from YOU About Manure and Compost:

If you use soil amendments such as manure or compost that uses animal waste, FDA needs to hear from you about how these proposed rules might impact your farm operation. 
 
How to Comment
 
You can comment online or by mail. For step-by-step instructions and help in commenting online, go to http://sustainableagriculture.net/fsma/speak-out-today/.
 
To comment by mail, type or hand-write your comments and mail them to this address:
Division of Dockets Management (HFA-305)
Food and Drug Administration
5630 Fishers Lane, Room 1061
Rockville, MD 20852
 
All submissions received must include the following:

  • Your Name
  • Your Organization (if any)
  • The appropriate docket number (the agricultural water and manure and compost regs are part of the Produce Rule):
  • For the Preventive Controls Rule: FDA-2011-N-0920 and RIN 0910-AG36
  • For the Produce Rule: FDA-2011-N-0921, and RIN 0910-AG35