1.) No one is guaranteeing the safety of anything; however, the program aims to develop scientifically defensible, regionally-based growing, handling and manufacturing practices – developed by a coalition of stakeholders including government entities, academics and the industry. These practices have NOT been developed. This proposal sets up the infrastructure by which a coalition of stakeholders can come to the table and develop those practices.
2.) The proposal, as is currently drafted would require that at least two “small” growers participate in the development of these practices.
3.) The “seal” is to be used primarily on bills of lading. California and Arizona have had a similar program in place for multiple years now; has anyone seen a USDA-approved “seal” on any of the leafy greens in the market? No. The seal is used on bills of lading so retailers know that the product in question was handled and grown according to the practices outlined in those state’s agreements.

Regarding transparency, there was an open comment period on the need for USDA to pursue a marketing agreement about a year ago. There has been a Web site – http://www.nlgma.com – on-line for about a year calling for stakeholders to provide comments on the proposal. Many of those comments and suggestions have been added to the proposed agreement. Furthermore, the proposed NLGMA has been prominently covered on the USDA AMS site. There was a Webinar where proponents explained the proposal and answered every question offered up by the more than 200 attendees, nationwide (the Webinar along with those questions and answers are available at http://www.nlgma.com). A large group of regional, state and national proponents have been communicating this process with their respective constituents for more than a year. The proponents called for, and USDA granted, a series of public hearings, across the nation, (which are ongoing) to discuss the merits of the proposal. I am not sure how this process could be more transparent.

There are a handful of different “metrics” or standards out there, and many of them are very costly. The entire industry needs to work toward one set of practices, defensible by sound science, which can replace those “super metrics” being handed down by the buying community. The National Leafy Greens Marketing Agreement would afford stakeholders that opportunity.

Lastly, this program is voluntary. If producers do not want to participate, they do not have to.

You dont have to subordinate yourself and your farm to the US government, its corporate run agencies in order to be successful.

What I have seen is that organic farmers don’t want to be accountable for the safety of their operations. That is why they manufacture the idea that food safety is a bad thing created by the large corporations.