‘Managing farm manures for food safety:
Guidelines for growers to minimise the risks of microbiological contaminati=
on
of ready to eat crops.’
Draft response from the Welsh A=
grifood
Partnership Organic Horticulture sub- group, 30th September 2004=
Ge=
neral
- Some =
of
the guidance could present significant practical problems for mixed
farmers, organic and conventional alike. We would welcome a wider deba=
te
on the level of risk posed by use of manure on ready to eat crops, aga=
inst
the practical implications of the guidance.
- To da=
te
we have been able to access only one of the papers on which this guida=
nce
is based (Stanfield and Gale, 2002). In our view it is an extremely
cautious document, which frequently points out the limitations of the =
data
on which its risk assessments are based. Moreover, while the document
attempts to model the decline of various pathogen populations in diffe=
rent
manures over time, it does not attempt to relate this to the risk they
pose. For instance, the report estimates that there might be 103 =
Campylobactor per tonne of crop, b=
ut
there is no indication of whether this represents a high, medium or low
risk to the consumer.
- At the
time of writing we were unable to access other information on which the
guidance is based, and are therefore unable to comment on this
specifically. We would welcome the opportunity to examine these report=
s in
the future.
- The
approach of the Food Standards Agency would appear to strive to attain
food sterility. We accept that at high levels, infections caused by th=
ese
pathogens are unpleasant and in some cases dangerous. However, we also
believe that low level of pathogens, presenting low level challenges to
the immune systems, do not present a threat, rather they are essential=
for
the development of a robust and healthy immune system. This approach is
fundamentally at odds with that of the Food Standards Agency
Specific
comments on the guidelines:
<=
/p>
Page 3: Stage 1 Minimising ri=
sks
before crop establishment;
Site
selection:
- Avoidance of fields recently
receiving manure or have been used for livestock grazing. This clearly has far reaching
implications for mixed farming systems, organic and conventional alike.
Mixed farming systems are widely accepted as contributing to sustainab=
le
agriculture, and organic farmers in particular rely on grazing livesto=
ck
to build fertility. We refer you to the Soil Association’s
assessment paper listed in the references for further details on the
practical problems the guidance would present.
- Minimizing airborne contaminat=
ion
by choosing fields that are not adjacent to livestock. The same issues apply as abo=
ve.
This guidance would make a mixed farming system practically unworkable=
for
many producers. In the light of this we would like to see further evid=
ence
to show that this measure would make a significant contribution to
reducing the risks posed to consumers.
Use of fresh manure:
- A 6 m=
onth
gap between application of fre=
sh
manure and harvest will probably not present organic growers with
significant difficulties. It is the case, however, that the introducti=
on
of such general restrictions reduces flexibility in cropping, with
particular implications for opportunities for catch cropping that might
otherwise occur.
- ̵=
6;You
should leave at least a 4-month gap between livestock last being in the
field and harvest of a subsequent ready to eat crop’.=
Livestock is a very large
category. Presumably this includes poultry, which are sometimes used f=
or
pest & weed control especially in fruit crops. Although most organ=
ic
growers will be able to comply, the regulation would place further
restrictions on growing systems
Use
of stored and treated manures:
- We wo=
uld
like to see FSA working closely with other organisations to actively
promote treatment of manures, in particular composting, on farms.=
- Lime =
treatment
would not be an option for organic farmers as the use of quick or slak=
ed
lime is prohibited under the standards.
Page 4
- The
guidance states that composting and treatment can effectively eli minate
most pathogens. What, therefore, is the justification for a 2 month pe=
riod
between application and harvesting for treated/ composted manure.
St=
age 2:
Minimising risks after crop establishment and during the growing season.
- Field
operations: Avoiding spreading manure on neighbouring fields would mak=
e a
mixed farming system totally unworkable for many producers. In the lig=
ht
of this we would like to see further evidence to show that this measure
would make a significant contribution to reducing the risks posed to
consumers.
Keep
livestock out of growing crops.
- This =
has
particular relevance for =
top
fruit growers. The Sustain project in Hereford has already made its views
known (see below for reference) on the issue and would concur with all=
the
key points they make.
References:
Stanfield,
G., Gale, P.
(2002) ‘Assessment of food safety associated with the spreading of an=
imal
manure and abattoir waste on agricultural land.’ Food Standards Ag=
ency
Soil Association: ‘Implications of prohibiting the grazing of
livestock with in one year of planting a ready to eat crop.’
Sustain: ‘ A new threat to our orchards; New guidance set=
to
destroy traditional orchards‘ Press
release 30th June 2004
&nb=
sp;