Saturday, March 29, 2014

Greetings,
I am getting in a hullabaloo with MAFRD (Manitoba Agriculture, Food and Rural Development) over the way they seem to be targeting small, artisanal food processors. I will write more about this in the future, but for now, I just want to post a copy of a letter that the Harvest Moon Food Society sent their friends and customers. This group of farmers, to my mind, exemplifies the ideal way to approach farming and eating in a sustainable, humane and socially responsible way. Yet, because they don't fit into one of MAFRD's narrowly drawn categories, their ability to market eggs and chicken has been cut off.

Here is the letter they sent:


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Dear Harvest Moon Local Foods Supporter,
As you navigate our web site to place your order this month, you are likely to notice that several items you are used to purchasing are no longer listed for sale. This letter is provide you with some background information on the reasons why we have had to remove some products.
In Manitoba, the 2 most common ways for farmers to sell their products directly to consumers are through a farmer’s market, or from the ‘farm gate’. Each method of selling has certain rules on what can and can’t be sold.

We have always believed that Harvest Moon Local Foods most closely aligns with Farm Gate sales, but because of our unique approach to selling food direct from farmer to customer thorough a web site alongside other farmers, there has been a lack of clarity on whether or not this is the case.
Our web site makes it clear which farmer a product is being purchased from and that farmer packs and delivers the product to a central point where it is delivered to the city on a single vehicle with products from other farmers.
In addition to these ways of selling, there are also different classifications of products depending on how they are processed. These products can only be sold farm gate.
  • Ungraded Eggs are eggs that have not been processed through a federally licensed grading facility. All eggs that were previously sold through Harvest Moon were ungraded.
  • ’Uninspected’ Poultry - this refers to poultry that has been processed at an abattoir that is a licensed food handling facility, but does not have provincial meat inspector on site to inspect the carcasses. There is currently only one abattoir for chicken in the province providing this inspection service that is accessible to small farmers. This facility is in Niverville, several hours drive from most Harvest Moon Farmers.
It is important to note that provincially inspected abattoir facilities for meat such as pork, beef and lamb are far more common and easy to access. All of these types of meat products for sale on our site come from inspected facilities and all our producers possess a ‘meat hawkers’ license.
There are a separate set of regulations that govern Farmers Markets. Some products found on our web site (processed foods such as jams, jellies and preserves that are made in a home kitchen) are able to be sold through farmers markets. Several of our farmers sell the same products that are available on our web site at Farmers Markets.
Earlier this year, we engaged provincial health inspection officials to seek clarity on our status. After reviewing each farm and what was for sale on our website, we were told that we did not fall under the ‘farm gate’ category and items such as ungraded eggs and uninspected poultry could no longer be sold. We have also been informed that we are also not considered a farmers market and therefore items such as the jams, jellies and preserves not produced in a commercial kitchen cannot be sold, even though these same products are able to be sold at farmers markets.
Here is our take on this outcome:
  • The inspectors are doing their job by interpreting regulations as they are written. While we disagree with their interpretation, we will respect the decision and hope to continue a constructive dialogue with them going forward.
  • The current regulations, in particular the definition of farm gate sales, have not adapted to ways of doing business in the 21st century. They present a barrier to small farmers and consumers who wish to do business directly with each other, they limit consumer choice in food purchasing and undermine the development of strong, sustainable local food system. Regulatory barriers such as these also discourage the entry of new small farmers into the market.
  • Food safety is a paramount concern for each of our farmers. No one in our group would ever compromise the well being of their customers or their own livelihood by improperly handling food or providing substandard product.
  • Our system is a model of cooperative marketing and pooling of resources that efficiently links farmers and eaters in a way that would be difficult for individual farmers to accomplish on their own. Instead of 15 farmers individually delivering products to the city or hundreds of eaters travelling to farms to purchase products, one vehicle travels to the city on one day.
  • The sale of product through the Harvest Moon web site and the transport of farm products in a single vehicle in no way compromises food safety, nor the transparency of which farmer the product was purchased from.
  • With over $120,000 in sales over the last year, our model promotes community economic development in rural Manitoba, the growth and stability of small farms and the promotion of local food choices. 2014 is the International Year of Family Farming and government should doing everything in its power to facilitate the growth and development of small family farms.
  Our plan moving forward:
  • For the time being, products such as eggs and uninspected poultry (any chickens that are for sale will be inspected) will not be available for sale from our web site. We strongly encourage you to contact farmers directly if you wish to purchase these products as they are still available from the farm gate.
  • We intend to work with government to modernize the existing regulations to accommodate these new ways of doing business.
  • We will keep you up to date as we make progress in our efforts.
We welcome your feedback and questions regarding these issues. Please visit the ‘Contact Us’ page on our website and select the subject box that says “Feedback regarding farm gate sales’, or email food@harvestmoonfood.ca.