We’re Putting the “Policy” in Food Policy Council

No really we meant “putting” as in “to put,” not “to putt.”  Anywho…

At the April leadership council meeting, your leadership council made some difficult decisions about how to prioritize our actions going forward.  The problem, more than anything, is that there is so much to do, and we’d like to do it all.  But in order to be effective, we felt we had to narrow our focus, at least for the immediate future.  With that in mind, we looked at a slew of policy issues that have come up, and analyzed them with the following criteria in mind:

  • How much excitement is there (both generally and within the LC) to accomplish this goal?
  • How important/tied to our mission is the goal?
  • Are there concrete achievements quickly and easily achievable within the goal?
  • How winnable is the goal overall?

With that said, here are the areas of focus of 2013!

Input on Sustainable Zoning Code and Animal Husbandry – The City of Tucson is updating their zoning code to incorporate some sustainable measures, including many food-related provisions.  Our members and associates (such as Merrill Eisenberg and Jaime de Zubeldia, to name a few) have had inp,ut in this process, particularly on the issue of raising animals within city limits.  The updates would loosen up restrictions and allow more animal husbandry within City Limits.  We may, however, run into some opposition from residents concerend about noise, for example.  If and when the City calls a public hearing on the issue, we want supporters to fill the room.  Check out the Tucson CLUCKS Facebook page, or just stay tuned with us and we’ll let you know when the next public hearing is.

Work with City of Tucson as “Convener” on STAR Goal – We were asked by the City of Tucson’s Office of Conservation and Sustainable Development if we would be the lead on the Food Access and Nutrition portion of STAR Communities–a rating system by which communities can assess their sustainability.  On May 29, we presented to the national community utilizing this system (about 30 communities across the U.S. and Canada), and highlighted a small portion of the work we’ve done in this community over the past 3 years.  Our future challenges within this goal will be to think of ways to push ourselves and to push the City of Tucson to continue this type of work.

Finalize, upload to the web, and otherwise distribute fact sheets on food policies – A number of fact sheets were developed under the CPPW grant (which ended spring 2012) by the policy team at the UofA (which helped start the food alliance).  They are in varying states of “doneness.”  We’ll soon by verifying the details of them, making any necessary changes, and sending them out for all to see.

Report on Water and Its Role in Urban Ag – We have an intern from the College of Public Health who’s been learning everything she can about water in Tucson–where it comes from, how much it costs, how urban and rural water rates differ, etc.  Her goal is to understand the role water can (and should) play in creating a more resilient and sustainable local food system.  She’ll be reporting back to both the leadership council and the general membership in the form of various blog posts.


What the New School Garden Guidelines Mean For You

The Arizona Department of Health Services recently released their set of guidelines for school gardens.  They’re still in draft form, but even so have far-reaching consequences.   We’ll attempt to break them down for you, in a sort of FAQ style.

Who is affected by these guidelines?

At this point, only schools.  And if you’re a school selling the produce at a farmers’ market (your own or someone else’s), you should be exempt, as long as your produce is whole, uncut, and unprocessed.  The guidelines are meant to regulate schools who aim to serve the food in the cafeteria, or any other type of “food establishment.”  Serving in the classroom is a bit of a grey area, from what we can tell.

Are the guidelines mandatory?  How are they enforced?

While they are still in draft form and are being called guidelines, they are mandatory.  A school must first is encouraged to go through a School Garden Safety Training, which is coordinated by the University of Arizona College of Agriculture and Life Sciences Cooperative Extension Maricopa County Extension.  After going through the (optional) training, the school can request an inspection from the Arizona Department of Health Services School Garden Sanitarian and Health Educator, Kathryn Mathewson (602-364-3952).

Are the guidelines permanent?

We’ve been told they are still open to changes, and the guidelines are in draft form.  At the same time, attempts to provide input on certain guidelines have so far been unsuccessful.

(Since publishing this post originally, ADHS has taken down the “draft” watermark initially embedded in the guidelines document.)

Why were these guidelines created?

“Food establishments” are required to serve food from an “approved source” in the state of Arizona.  There is, however, no definition for “approved source.”  Absent that, ADHS has generally deferred to the State Department of Agriculture by encouraging farms to go through Good Agricultural Practices (GAP) training and certification.  These guidelines, however, require a huge amount of documentation, testing, and other activities, all of which require an essentially fixed cost or amount of time, regardless of the size of the operation.  In addition, inspectors are few and far between and charge by the hour, meaning an inspection for someone (esp. in northern Arizona, where there are no inspectors) can cost hundreds or even thousands of dollars.  For all these reasons, small farmers, backyard gardeners, and school growers have considered GAP certification to be an overly onerous process.

In 2011, the Pima County Health Department changed their interpretation of the food code to consider school gardens an approved source.  Since then, ADHS took it upon themselves to further define “approved source” in the context of increased focus on school gardens.  These guidelines create a standard for school gardens around the state, but do not apply to any other operation growing food.



With those facts out of the way, let’s delve into some of the more controversial aspects of the guidelines, which will involve some opinion on our part:


The use of school-made compost on edibles is currently banned by the guidelines.  If it is used at all, it must be purchased commercially.  The ostensible reason for this ban is that compost piles that are not managed properly–especially those containing animal products such as manure–can contain pathogens.  The reasoning is that some of those pathogens may make their way into the food.

Problems with this line of reasoning are numerous.  If the underlying assumption is that compost is highly dangerous, that threat is being far overblown.  Composting has been around for thousands of years and has been understood to be a safe process for decades within the scientific community.  To suggest otherwise, as these regulations do, is anti-science and flies in the face of many institutions that encourage composting, such as City of Tucson, Pima County, ADEQ, the EPA and USDA.

There is also the question of cost.  Because of the low organic matter content of our soils (less than 1%), a 50/50 mix of compost is needed to start a successful vegetable garden.  Purchasing organic compost for a modest garden of four 4′ x 10′ beds can cost upwards of $500 (with bagged compost from Home Depot).  Soil amendment is a recurring need, so schools will continue to incur costs each season if they are required to purchase compost, making gardening an unnecessarily–and possibly prohibitively–expensive activity.

At the end of the day, schools are not necessarily any better off acquiring compost from a commercial source, as there is no regulatory body that oversees composting in this country.  (Apparently it has never been enough of a problem to warrant it.)  In addition, the food that already enters the cafeteria is being grown with compost.  Or if not compost, chemical fertilizers.  Ironically, ADHS DOES allow chemical fertilizer use in school gardens.  Hardly a safer alternative, but when an agency focused on food safety and biological disease outbreaks begins regulating farm practices, this is where we end up.


The regulations allow “surface water” to be used if it’s tested at least 3 times over the course of the growing season.  Surface water is essentially any rainwater that has run off and collected somewhere, usually in the form of a lake, stream, river, ocean, etc.

In a somewhat contradictory statement, ADHS makes a special exception for “collected rainwater,” stating that it is not allowed at all.  On another section of their website, they explain, “While the guidelines do not discuss rainwater, but [sic] it is highly recommended that rain water is not used on edible plants due to bacteria, viruses, protozoa, and chemicals that can be found on roof tops and grow in the collection container.”

There is no citation given for this claim.  The American Rainwater Catchment Systems Association disagrees, however, stating that a properly designed system provides a source of clean water that is actually superior to most municipal water for growing plants, as it contains no ammonia, chorine, or flouride.  In addition, in our desert area where soils are very alkaline, the relatively low PH of rainwater helps create a neutrally balanced soil and encourages uptake of essential minerals, making plants healthier overall.

With simple best practices in place, schools can and should be harvesting water for use in gardens (vegetable, or otherwise), orchards, landscaping, etc.

Non-Latex Gloves

The guidelines require that non-latex gloves be worn by gardeners.  Disposable gloves have become a standard in the food prep industry, and indeed, when dealing with ready to eat foods, they are the best way to prevent contamination.  However, non-latex (we assume they mean “disposable”) gloves are inappropriate for use in the garden.  Requiring their use prevents gardeners from using actual safety gloves where necessary and thus present a hazard to the child.

Other versions of these guidelines referred to a non-latex disposable glove requirement when harvesting.  This too seems, unnecessary at best, and harmful at worst.  The state of Arizona already makes a special exception for whole, uncut produce to be sold directly to the consumer, precisely because produce in this form has little risks associated with it.  Produce must, at minimum be washed, and in many cases processed in some other type of way, before it is consumed.  It is, therefore, not a “ready-to-eat” food that requires the use of gloves.  Additionally, in the hot climate of Arizona, disposable gloves encourage excessive sweating and may actually increase the chances of bodily fluid transfer.

On being able to find child-sized non-latex disposable gloves, PCFA’s resident Chef Elizabeth Mikesell simply said, “good luck.”  Hence, from both a safety and a practical standpoint, this requirement makes little sense.



While we applaud ADHS for its attempt to make food production safer, we suggest they seek input from those actually working with students and those engaged in food production–teachers, school and backyard gardeners, and farmers.  What’s your opinion on the matter?  Leave us a comment a below.

The Difficulty in Defining Local, as It Pertains to MyPlate

During our MyPlate project—our attempt to experiment with USDA’s MyPlate project in our local food context—some tough questions came up.  The first question was, obviously, “What does local mean?”  We also grappled with the oft-criticized decision by USDA to include milk as its own, separate component.  What follows is a brief description of those debates we had, and the guidelines we came up with for this project.

Question 1: How do we define local?

We chose to define local loosely, to mean, anything you can grow in the immediate area surrounding Tucson.  Considering the vast elevation differences between the desert floor (~2000 ft above sea level) and some of our mountain ranges nearby (~9000 ft above sea level), coupled with varying weather patterns, we actual have a pretty broad scope of ingredients to choose from during any given season.  That said, we tried to, for the most part, to ask the question, “Could I grow this in my backyard during x season?” as a way to answer this question.

Question 2: What about native or heritage foods?

We chose to differentiate between local foods—anything that can be grown locally—and two other categories of food.  Native foods are foods that are indigenous to this area and have been around for hundreds, even thousands of years.  We decided to also pay respects to the slew of foods brought over during the 1600 and 1700s (starting with European explorers and missionaries) that later became part of the local and cultural food ways.  We called these foods heritage foods.

Question 3: Is there a breakdown of ingredients by season?

Yes!  Keep in mind this is a work in progress, and may contain mistakes here and there.  But if you’re interested, check out our google doc of local, native and heritage foods by season.

Question 4: How strictly should we adhere to our definitions in acquiring our ingredients?

We we were not strict on basic spices and oils.  For ingredients that we felt, somewhat arbitrarily, should be considered “main,” we stuck to the “can it be grown/produced here” rule of thumb.

Question 5: Why is there no milk in your MyPlate meals?

USDA has been criticized often for its decision to bend to the will of the dairy industry and include milk as its own component, on top of the protein section.  We had similar reservations, and decided to go with a slightly different version of MyPlate, one produced by the distinguished (and arguably less-biased) Harvard medical school.  Here is there Healthy Eating Plate (and a description can be found here):

Harvard Healthy Eating Plate

Let us know if you have any questions!

Leadership Council Applications: In Process!

[Update: Our deadline has passed and we are currently reviewing a batch of great applications.  We’ll get back to you soon, so stay tuned!]

The Pima County Food Alliance is excited to announce  that it has new openings on its Leadership Council.  This is a great opportunity for community members to continue leading in the development of a vibrant and just food system in Pima County!

Please take a look at our Leadership Council Announcement and Application if you’re interested in applying and get back to us by the end of the day on Sunday, January 13th.  We’d love to hear from you!

In case you’re curious, here’s a look at  the 2012 PCFA Leadership Council, many of whom will be staying on.