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?
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.
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.