On Wednesday, January 15, the Arizona Department of Health Services (ADHS) released updates to its school garden program guidelines, which guide how food must be grown in schools in order to be served in the cafeteria. This was a long process of negotiation, and we’re extremely happy with the outcome, as our three areas of concern have all been dealt with:
1. School-made compost now can be used to grow food for the cafeteria;
2. Rainwater now can be used as a source of irrigation water;
3. Non-latex disposable gloves are no longer required for harvesting; just proper hand-washing.
That said, schools will still need to get certified by the state school garden sanitarian and show they are maintaining the compost and rainwater up to the standards specified. You can find more details on the ADHS School Garden page, specifically with the Program Guidelines and the Food & Garden Safety page.
It’s a lot to sift through, so let us break it down for you with some broad generalizations, FAQ style:
What’s all this business about SOP’s and Attestations on the Food & Garden Safety page?
SOPs are standard operating procedures. ADHS has provided sample SOPs for your benefit. They are based on good science, so if you want to copy (and follow!) them word for word, you’ll be in good shape. However, they are not hard and fast rules. You can tweak them a little or make up your own from scratch.
The attestation is, first and foremost, a form you sign to attest that you will actually do what you say you’re doing in the SOP. Someone—ideally an individual closely involved with the garden, or the school principal—needs to sign the form and send it back to ADHS. Unlike the SOP, the rules listed on the attestation ARE hard and fast. If you decide to alter or write your own SOP, you need to make sure it at least follows the parameters set forth in the attestation.
What are the regulations for school-made compost?
School-made compost can now be used, so long as the school follows proper protocols. In a nutshell, this entails getting the pile to a high enough temperature, which happens naturally through microbial processes when the proper ratios of materials are added. For plant-based piles, 131 degrees (F) must be reached for 3 days; 15 days for compost piles with manure in them. These temperatures are easily reachable if you have a large enough pile and are balancing the input materials properly.
There are some other guidelines in there, such as keeping your compost pile a safe distance from flammable structures, since there have in fact been cases of compost spontaneously combusting. Also, washing hands and tools properly after handling compost. Things like that.
What are the regulations for using rainwater?
Rainwater can now be used to grow food for the cafeteria. We had quite a bit of conversation with ADHS about whether the water would need to be tested first. The end result is this: Testing is only required if you’re applying the water directly to the plant such that the edible portion is at risk of being contacted AND your rainwater is coming from a poorly designed and/or maintained system.
Another way of stating that is that if you have a well-designed and maintained system that meets their standards, you’re good to go! Alternatively, regardless of your system’s design, if you’re careful to apply the water directly to the soil (e.g. via drip irrigation), you’re good to go! No testing.
Pretty doable, we think.
What about gloves for harvesting?
Non-latex disposable gloves are no longer required. However, proper hand-washing will be required and as such, you should consider holding a proper hand-washing training with your students. In addition, harvesting equipment will need to be cleaned and sanitized between uses, so use hard plastic or metal containers, rather than, say wicker baskets.
What do we need to do to actually start serving food in the cafeteria?
Probably the biggest hurdle will be getting all your policies together into a central place, and making sure everyone is following them and keeping track of them. Consider making a binder and holding trainings for other teachers and students to cover the essentials.
With the unfortunate but very real danger of litigation in our society, documenting your practices will be essential. You’ll need to keep track of harvest days, trainings, soil history, etc. If you’re using your own compost or rainwater, you’ll need to keep track of temperatures for your compost piles, days when you emptied out the first flush on your cistern system, etc.
Once you have all your ducks in a row, you can contact Kathryn Matthewson at ADHS and request a site visit. Once she inspects your garden and gives you the green light, you’re free and clear.
What about other policies, like that of my local health department of school district?
You should clear your plans with your own district leadership before attempting to bring garden food into the school cafeteria. Following the guidelines put forth by ADHS though will put you in a good position. For example, in working with Tucson Unified School District, they have stated that they will abide by ADHS’s recommendations.
As for your local county health department, ADHS has been in touch with all the counties across the state and is taking care of all the legwork by providing an ADHS sanitarian to do the school garden certifications. Furthermore, the counties cannot make policies that contradict those of the state health department. As such, we feel confident in saying that if you follow ADHS’s guidelines for school gardening, you’ll be in good shape.
Is all this really worth the trouble?
Kids who participate in Farm-to-School programs do better academically on average, have fewer behavior problems, increase their knowledge, and develop healthier eating habits, according to many studies. Making the leap from the garden to the cafeteria helps kids make a difficult connection: that the food they eat both at home and in the cafeteria has the potential to be every bit as awesome as the food they’re so excited to grow in the garden. Cafeteria integration is a key part of Farm-to-School around the country and this new ruling clears the way for Arizona’s schools to make some really good headway.
Update: The application period is now closed. We’ll have more openings around Christmas later this year, so be sure to check back in!
The leadership council is the place where decisions get made for the Pima County Food Alliance, and where much of the exciting work and coordination actually gets done. We are a roughly 16-member body that meets monthly to discuss projects, share information, talk about partnership opportunities, and figure out how to accomplish our food-related goals.
This year, we’re interested not only in people with extensive food systems experience, but also people with event planning and facilitation experience. Why? During 2014 we’d really like to bring back the general meetings in some form or another, after our long hiatus. We think it’s great for people to get together and talk food, network, and learn—we just want to make sure it’s done in the most useful way for everyone. Another key area we could use help is with our internal communication and organization.
So regardless of your level of food systems experience or expertise, if you think you can contribute in either of these areas, please consider applying. Applications can be downloaded here, and submitted, with a résumé, back to us at email@example.com.
[This blog entry was jointly written by Marisa Tacket, our water intern, and Nick Henry, one of our leadership council members.]
With this blog series, we aim to answer the question of whether and how water can be responsibly used to support a robust local food system. Before going there, we should look at how water is currently being used for agriculture in Arizona.
The topic, as you can imagine, is weighty. Agriculture in Arizona is a $12.4 billion industry, with much of that revenue concentrated across a small number of large farmers (only ~1,000 farmers generate more than $500,000/year). In total, farmland makes up about 35% of Arizona.
The top agricultural products by gross revenue are alfalfa, cattle, dairy, lettuce and cotton. Let’s take a look at a couple of them in terms of water use. Cotton is grown on approximately 200,000 acres around the state, an area of land slightly larger than Tucson. Over the course of a season, cotton requires about 5 vertical feet of flooded irrigation water per acre of cotton (in other words, 5 acre-feet). That makes for a total of 1 million acre-feet of water for cotton per year. By contrast, last year Tucson Water’s entire service area used only 140,000 acre-feet. Put another way, a small group of Arizona cotton growers uses seven times as much water as all Tucsonans combined.
The picture isn’t much better looking at the other top products. Alfalfa requires almost as much water as cotton and the lettuce industry uses half the land area of Tucson but twice the water. [i],[ii] Beef is one of the most water-intensive foods on the planet and yet Arizona produced 413.7 million pounds in 2010.[iii],[iv],[v], In total, this required more water than all domestic uses in Arizona combined, and over 100 times as much water as Tucson alone. (Though it should be noted, that calculation includes water for growing feed, much of which is grown elsewhere and imported into Arizona.) Overall, 69% of the state’s water goes towards agriculture.[vi]
The Source of our Water
Hearing all this, you might be asking, “Where does all this water come from, and how much does it cost?!?” We’ve already talked quite a bit about water from the Central Arizona Project—Colorado River water piped into the interior of the state. The other major source is groundwater, which became widely available during the 1930 and 40s as windmills were replaced by pumps run on cheap electricity.
As groundwater became available, lawmakers struggled to provide a legal framework to define and manage groundwater rights. The Groundwater Management Act (GMA) was finally implemented in 1980, which called for regulations and a permitting process within newly established Active Management Areas (AMAs). Within each AMA, conservation was to be included in the management plans, as overdraft was becoming already becoming an issue.
While greater efficiencies have been achieved, that hasn’t necessarily translated to more conservation (or significantly less overall water use). The GMA was a giant step in the right direction, but also has some serious shortcomings. To name a few:
- Water rights were given to users who’d already been pumping groundwater based on peak usages from the period of 1975-80.
- Unlike in some other states, groundwater is treated as a completely separate class of water from surface, when in reality the two are tied—serious decreases in one and can lead to decreases in the other. Thus, encouraging heavy CAP use may actually decrease the availability of groundwater in some areas, and vice-versa.
- Groundwater is basically unregulated outside of the Active Management Areas, many of which are now sucking water at alarming rates.
- A water credit system was put into place. In years when farmers were discouraged or required by federal programs to leave a field unplanted, rather than saving water, they could accumulate credits for future water use or sell the credits so others can use extra water.
- Groundwater rights are transferrable, and certain types (including those for livestock) can be sold independently of land.
Overall, this has led to a situation in which “growers felt no constraint on their irrigation water usage” (Frisvold, Wilson & Needham, 2007) and overall water consumption has slowed down insufficiently.
The Cost of our Water
In an effort to relieve the burden on groundwater resources, CAP water has been pumped in at low cost to agricultural users for the past decade, starting out at $17/acre-foot and rising a dollar per year. Tacking on all the additional costs associated with CAP water today, irrigation districts generally charge in the vicinity of $45-65/acre-foot of water.
To give a little perspective on these numbers, let’s compare it to domestic or municipal use. Municipalities in Pima County pay a base rate of $161/acre-foot to access CAP water. Factoring in all the other costs, the average Tucson Water user is charged a rate of $561/acre-foot (they consume far less than that per month, obviously). For higher volume users, tiered pricing kicks in, and this number can increase by a factor of 10.
In other words, farmers pay somewhere between 1/10 and 1/100 the price municipal users pay for CAP. While these low prices might, from a certain perspective, seem unfair, they have helped ease the burden on groundwater use. Today, CAP supports about 300,000 acres of agricultural land, or approximately 36% of our total harvested croplands.
However, as drought continues and water rates increase, farmers are switching back to groundwater. The overarching problem is that farmers have always had, and still do even under the GMA, access to all the groundwater they can use, at next to no cost. Other than permitting their wells and paying for upkeep on infrastructure and the cost of energy to pump the water, the water is basically free. The only long-term limit is whether the water table gets sucked dry, and how far down you can drill to keep accessing the water. Federal subsidy and commodity support programs have only exacerbated the problem, allowing Arizona growers to turn a profit while converting their 3-5 acre-feet of water into crops that bring as little as $20/acre on the market.
Much of the legal system that governs water use was hammered out when water was considered a virtually infinite resource and the rights to it an issue of private property. Today, it’s become increasingly clear that water is, in fact, a public resource, and one on which we all depend. It’s time to start rethinking the way we use it, especially as it pertains to our food system.
[Next post: How can water be used to relocalize our food system?]
[iii] Estimates for water use in beef production range from 1,801-12,009 gallons of water/pound of beef. Arizona farmers harvested 413.7 million pounds of beef in 2010, which in terms of water use means somewhere between 2.28-15 million acre feet.
[v] Gallons of water per pound of beef were quoted as 12,009 in Stephen Grace’s book “Dam Nation.”
Pima County Food Alliance is taking part in a national study, conducted by Active Voice, to better understand what it takes to address hunger, obesity and food insecurity, and we’d like your help to get a better picture of what people know about these issues in our community.
We would like to ask for your participation in this Community Study by completing two time-sensitive steps at this time.
STEP 1 – Local Organization Questionnaire #1: please complete by Tuesday, September 17th – Local Organization Questionnaire #1 (CLICK HERE)
STEP 2 – We also ask your help in sending the email below to members of your network and community listserves, including any residents of your community, within the next 48 hours (SEE DIRECTIONS BELOW). This may include sending an email blast to your online contacts and/or posting the link on your social media feeds. The more widely spread it is the better. Please see directions below on disseminating this survey.
About the Study: The Take Your Place (TYP) Community Study involves 24 communities across the U.S. where at least one free screening of the film “A Place at the Table” is being held this summer or fall. Participation in the Community Study consists of completing three brief questionnaires over an 12 to 16 week period. Each questionnaire will take about 10 to 15 minutes to complete. Participation is voluntary and your responses are confidential.
Community Study participants who complete the questionnaires will have the opportunity to win the following prizes:
Questionnaire #1 (due Sept. 17): $100 Target Gift Card
Questionnaire #2 (down the road): $100 Target Gift Card
Questionnaire #3 (further down the road): $200 Target Gift Card
If you have any questions regarding the Take Your Place Community Study, please contact Active Voice Research & Evaluation Manager, Dina de Veer at firstname.lastname@example.org or 415-487-2000.
DIRECTIONS for Survey for your Individual Members:
1) Copy and paste ALL of the text from this blog post into a new email.
2) If you need a graphic, feel free to use the image below.
3) Edit the “Subject” line of the email to: “Take Part in Community Study; chance to win Target Gift Card”
4) Send widely!