USDA Considers Leafy Green Rules

Uniform leafy green rules could be burdensome to small-scale growers. Corncopia offers ways to provide feedback.

by Dani Yokhna
Submit comments on proposed USDA leafy greens rules
Courtesy Scott Bauer, USDA

How to Submit Comments
The USDA is asking citizens to comment on its plan to implement these rules.

In your comments, it’s important to: tell the USDA that you want to ensure access to fresh, leafy greens and that you oppose a Marketing Order or Marketing Agreement that would impose federal standards for all growers of leafy greens.*

Cornucopia Institute also offers instructions for submitting your comments.


  • Download sample letter, post online.
  • Fax: (202) 720-8938. 
  • Write your own letter, post online

*Letters should reference Docket Number AMS–FV–07–0090.

To Submit Online:

Subscribe now

  • Go to
  • In the middle of the screen, you’ll see “Search Documents.”
  • In Step 1, choose “Documents with an open comments period.”
  • In Step 2, choose “Department of Agriculture.”
  • In Step 3, choose “PROPOSED RULES.”
  • In Step 4, choose “Docket ID” and then type in “AMS-FV-07-0090.”
  • Hit “Submit.”
  • Next, you will see a column titled “Comments, add/due by.”
  • Click on the tiny tan dialogue icon, and you are now ready to submit your information and your comment.

USDA is considering federal rules that could potentially require growers of all leafy green vegetables to follow specified guidelines in fields and during post-harvest handling.

The rules are considered an attempt to help control outbreaks of disease–such as the E. coli outbreaks in 2007.

Such rules could be compared to other broad-based rules that could be more easily managed by large-scale producers but could be financially burdensome to small farms.

Concerned citizens have until Dec. 3 to weigh in on the proposal, released by the USDA as an Advance Notice of Proposed Rulemaking (ANPR).

According to Cornucopia Institute, a nonprofit farm policy research group, the requirements could mirror those already in place in California.

The leafy green measures are described as “unproven in terms of their impact on food safety” and would likely dictate uniform growing practices and food safety measures that might be appropriate for large-scale farms, but could hurt family farms that are already focused on growing leafy greens in a healthy and environmentally sustainable way.”

One possible effect of the rules: required testing for pathogens at every harvest.

The leafy greens rules are being compared to the rules that mandate the pasteurization of almonds grown in Californian by chemical or heat treatment, which has been a substantial financial burden to many small-scale farmers.

Read more on this topic at the Cornucopia website.

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