Policy Analysis
The order of the political analysis relative to the social analysis section of this report is not arbitrary. While local, state, and federal policies can force LaFarm’s short-term and long-term goals, an understanding of LaFarm’s function within the context of its relationship with the Lafayette and Easton communities influences how policies are interpreted. This section seeks to articulate the policies that shape the short-term and long-term visions for LaFarm. Additionally, this policy analysis addresses the stakeholders, and policy-actors most likely to influence the decision-making process and eventual execution of a wash station.
Policies Warranting & Influencing the design of a Wash Station:
Food Drug Modernization Act (FSMA)
The Food Drug Modernization Act (FSMA) was signed into law in 2011 in an effort to better prevent food contamination rather than respond after the fact. As a result, new food safety standards have been updated and implemented to address the practices associated with growing, harvesting, washing, packaging, and preparing of foods. The act does not adopt a one-size-fits-all policy and recognizes that requirements necessary for a large scale facility imposed on small scale operations could be detrimental to the agriculture industry. In short, LaFarm is exempt from most requirements imposed on large-scale operations (>$1,000,000 in annual revenue), but nonetheless serves as a template for neighboring small-scale farms that will increasingly have to comply with federal oversight of good agricultural practices.
The most pressing regulatory pressures imposed on ambitious small scale farms include the need to ensure safe food practices during the growing, harvesting, washing, packaging, and preparing stages of on-farm food preparation. FSMA creates new regulations for produce production and food safety measures for facilities. In general, this refers to two specific rules established by FSMA: the Preventative Controls Rule and the Produce Rule.
For facilities that manufacture, process, pack, or hold human food should follow requirements imposed by the Final Preventative Controls Rule. This rule revises Hazard Analysis and Risk Based Preventative Conrols as well as Current Good Manufacturing Practice (GMP) requirements. Fortunately, farms similar to LaFarm are exempt from this rule as a result of meeting the definition of a farm rather than a facility. A primary production farm is an “establishment under one ownership in one general physical location devoted to the growing” and “harvesting of crops,” and may also pack and hold “raw agricultural commodities” (FDA, Sept. 2015).
Most importantly, all farms should comply with the Final Rule on Produce Safety (Produce Safety Rule) that regulate aspects such as agricultural water, biological amendments, farm health and hygiene, as well as equipment and buildings that impact the growing, harvesting, packing, or holding of produce. The main points of this rule are to ensure that agricultural water is treated and tested both on a routine basis (a minimum of one sample per year); soil amendments are used appropriately; actions are undertaken to prevent contamination of vulnerable sprouts; that workers are adequately trained with regards to health and hygiene; and that measures are taken to prevent contamination of produce by equipment, tools, and buildings (FDA, Nov. 2015). This is informative for LaFarm, because it establishes agricultural water testing and enhanced hygiene as the two issues most inadequately addressed.
Produce Safety Standards under FSMA require that LaFarm’s harvesting practices comply with the Produce Safety Rule. Additionally, the FDA has provided a Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables. In the case of small scale farms akin to LaFarm, facilities can meet standards by achieving Good Agricultural Practices (GAP) and Good Holding Practices (GHP) certification by a third party-auditor. Applicable requirements expressed in the audit checklist for GAP & GHP certification pertaining to a wash station includes the ability of the farm to ensure that the water used is “microbially safe,” that source water in the packing operation is “potable” (USDA, 2014). If a wash station is to serve the dual purpose of packing, additional requirements need to be met for the development of a packing house. These include that the packing facility be “enclosed” placed away from employee facilities, and garbage receptacles (USDA, 2014).
While many other facets of LaFarm are the under scrutiny of FSMA and GAP & GHP guidelines, only the most pressing issues should be addressed in an effort to make LaFarm more compliant with federal regulations. It is because of this that the development of a wash station is necessary. LaFarm and many others like it must be able to test the water that is used to wash harvested produce.
Building Codes
The Pennsylvania Department of Labor & Industry exempts agricultural buildings from having to meet construction codes within the Commonwealth of Pennsylvania. Agricultural buildings refer to:
“A structure utilized to store farm implements, hay, feed, grain or other agricultural or horticultural products or to house poultry, livestock or other farm animals, a milk house and a structure used to grow mushrooms. The term includes a carriage house owned and used by members of a recognized religious sect for the purposes of housing horses and storing buggies. The term shall not include habitable space or spaces in which agricultural products are processed, treated or packaged and shall not be construed to mean a place of occupancy by the general public” (DLI, 2008).
A wash station and similar operating facilities on a small scale farm like LaFarm most likely fall under the definition of agricultural building given that they are distributing raw agricultural products rather than “processed, treated, and packaged” products.
Policy Actors:
Lafayette College represents the most influential organization. Within Lafayette College, there are extensive groups of interconnected departments and faculty with direct control over the daily operations and long term goals of LaFarm. Most importantly, all of these divisions work together to finance and implement projects at LaFarm. These include:, Sarah Edmonds, Garden Manager; members of the LaFarm Advisory Board; the Office of the Provost; Dining Services; the Department of Facilities Planning and Construction; academic departments such as Engineering Studies, Civil & Environmental Engineering, & Environmental Science and Environmental Studies; as well as the Plant Operations Division.
In addition, student organizations represent key groups of interested students with an uncanny ability to raise awareness within the Lafayette community. These include: The Lafayette Food and Farm Cooperative (LAFFCO); Lafayette Environmental Awareness and Protection (LEAP); and The Society of Environmental Scientists and Engineers (SEES).
Apart from Lafayette College, additional individuals and institutions both legally and fiscally have a notable say in the daily and long term operations at LaFarm. For example, the FDA Food Safety Modernization Act (FSMA) sets the standards for facility registrations associated with the manufacturing and preparation of produce and is enforced by the FDA and third party organizations. These include: The Ludwick Family Foundation; Art Hendrickson ‘51; Bon Appetit Management Company; US Food and Drug Administration (FDA)
Before considering the technical design and the economic analysis, it is pertinent that an understanding of the policies most heavily influencing the design process are understood. In this sense, the political context informs the decisions made in the rest of the report. The social analysis involved understanding the social, historical, and environmental factors that define LaFarm: its relationship with the communities of Lafayette College and Easton and, thus, its purpose. Lafayette’s rich historical ties to agrarian practices, environmentally conscious student body, and role as an educational institution as well as a natural lab for innovation heavily influences any project that is undertaken. Based on the social analysis, LaFarm is understood to be a template for other small-scale farms. This informs any group tasked with improving LaFarm to consider LaFarm as a “primary production small-scale farm,” which informs further decisions on the basis that certain federal regulations under acts such as FSMA are exempt for LaFarm and the other small-scale farms it hopes to inform.