EH and Food Access Finding the sweet spot between the three goals

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1 Justin Malan, Executive Director, CCDEH / CAEHA Talk hosted by Public Health Alliance of Southern California EH and Food Access Finding the sweet spot between the three goals

2 Much like the other triple bottom line People Planet Profit

3 Food safety has recently been on everyone s lips

4 Obesity has become the new epidemic

5 Concerns grow over industrial scale agriculture

6 With no easy solution in sight

7 CCDEH Envisions Safe, Secure and Sustainable (S3) Foodsystems The First Three Symposia San Diego 2010; Monterey 2011 And Riverside 2012 Catalysts for a new dialogue Environmental Public Health learn to look outside of the box Foodies learn to look inside the box Sacramento May 2015

8 Lots of questions some answers started to emerge Is a goal for a safe, secure and sustainable foodsystem in California meaningful and valuable? Is a goal for a safe, secure and sustainable food system realistic? Are there any parts of these core attributes that you would consider to be mutually incompatible? What do you see as the most pressing challenges to achieving an S3 foodsystem? Do you have a proposed approach to overcoming these?

9 Some answers started to emerge locally and nationally Food Safety Modernization Act- January 2011 Obesity campaigns surge California enacts AB 581 and other access laws Grow local food movement Foodsheds proliferate Legitimization of Cottage food in AB 1616 Direct agriculture marketing picks up steam CDFA year-long advisory group meetings

10 Some core issues for the Public Health Community to tackle Pros and cons of Clean Farms Radiation and GMOs Promoting healthy foods and healthy lifestyles Meeting the Approved Source requirement What is Risk-based management Role of government oversight vs. personal responsibility Regulatory Consistency a goal for all cases?

11 FOOD SAFETY WHAT CHANGE TO IMPLEMENTATION OF CURRENT APPROACH WOULD YOU WANT TO SEE? -- International -- Federal -- State -- Local

12 HEALTHY FOOD ACCESS WHAT CHANGE(S) TO IMPLEMENTATION OF CURRENT APPROACH TO HEALTHY FOOD ACCESS WOULD YOU WANT TO SEE?

13 SUSTAINABLE FOOD PRODUCTION WHAT CHANGE(S) TO IMPLEMENTATION OF CURRENT APPROACH TO SUSTAINABLE FOOD PRODUCTION WOULD YOU WANT TO SEE?

14 SUSTAINABLE FOOD PRODUCTION WHAT CHANGE(S) TO CURRENT LAWS AND REGULATIONS GOVERNING SUSTAINABLE FOOD PRODUCTION WOULD YOU WANT TO SEE?

15 Filling in some regulatory gaps.

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17 But some we do and possibly get closer to our S3 goal

18 CFMs, community and school gardens and CSAs

19 What s covered in CalCode & what s not? Disparity in local interpretation of Approved Source for direct ag sales Absence of statutory definition for farm; registered grower; gardens, CSAs, etc. Need to reconcile public health and agricultural commodity approach to direct or retail and indirect/wholesale operations What constitutes sale to general public? Compliance with the federal Food Safety Modernization Act

20 Generally OK No change proposed for off-farm food processing (Indirect or wholesale). Full state and/or local permits required Retail Field Stands and Farm Stands: Generally adequately covered under existing law (CalCode Sections et seq.) Certified Farmers Markets (CFMs): Generally adequately covered under existing law (CalCode Sections et seq.) Value added/cottage Food: In compliance with AB 1616 Technical amendments to AB 1616

21 Generally not! Approved Source for small scale agricultural products Community Supported Agriculture - CSAs (Veggie boxes) Gardens: Victory; community; culinary; school etc. Off-farm roadside vendors Food sale adjacent to CFMs Raw milk dairies

22 Approved Source All produce from a farm regulated by CDFA (and DPR) is considered an approved source under CalCode All produce (uncut fruit and veggies and unrefrigerated raw eggs) grown in non-farm area in compliance with all federal, state and local regulations plus CDFA Best Management Practices (BMPs) considered an approved source

23 CCDEH s approach on AB 1616 AB 224, and AB 1990 AB 1616 (Gatto) Cottage Food Act Allows Direct and Indirect sales of listed non-potentially hazardous foods prepared in private home to be sold to general public. Two tiers of oversight (Class A and Class B). Sales capped at $35,000 to $50,000 per year. Locals partially preempted. AB 224 (Gordon) 2013: Community Assisted Agriculture (CSAs): Support three-tier structure based on product and source. Addition of Value-added products to be in compliance with AB All CSAs subject to basic food safety requirements for traceability, labeling, prevention of contamination

24 CCDEH s approach on AB 1616, AB 224, and AB 1990 Potentially Hazardous Foods that are not USDA/CDFA exempt and sold through Direct Ag Marketing or CSAs that do not qualify for Direct Ag Marketing exemption (produce bought through wholesale or out of state) require full state/local processing or retail food facility permit USDA/CDFA Exempt rabbits and chickens plus USDA cut and wrap meats to be included in a self-certification BMP. Raw milk: Not to be regulated by local agencies. Only allowed for sale if through herd share concept where sales are limited to non-general public or herd shareholders. UNRESOLVED

25 CCDEH s approach on AB 1616, AB 224, and AB 1990 AB 1990 (Gordon) Gardens & small plot operations (including culinary, community, victory, and no sales/donations to public exempt from CalCode permit If sales/donations to public (Inc. SCHOOL GARDENS) subject to adherence to BMPs/GAPs. Sales by grower to restaurants OK with GAPs. Considered direct sales under AB 2168

26 Outstanding Issues: Best Management Practices(BMPs) or Good Agricultural Practices (GAPs) (San Diego, Berkeley, Napa and others have local ordinances/conditional permits) To be drafted (in consultation with CDPH and CCDEH/HOs) and posted on CDFA website Complaint response/inspection and recall authority with local Public Environmental Health subject to cost recovery

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