A year ago, when President Obama signed the Food Safety Modernization Act (FSMA) into law, it remained unknown what mechanisms the FDA would use to police this sweeping reform of U.S. policy on the safety and health conditions that our food experiences during growth, harvest, storage, and transportation. The reforms were largely prompted by recent preventable outbreaks of food poisoning caused by bacteria such as E. coli and others.

The bill mandated changes, including giving the FDA the ability to directly issue a food recall, increasing inspections of food production facilities and ingredient tracking. Most pertinently for farmers in the Willamette Valley, it set new national standards for growing and harvesting fresh produce.

“The concern was microbial contamination of our food supply,” Elanor O’Brien, of Persephone Farm in Lebanon, Oregon, says of the FSMA.

“A lot of contamination comes from fecal matter, so there’s a huge emphasis on personal hygiene—people who are sick shouldn’t come to work. And then of course there’s feces from birds and wildlife,” O’Brien explained. One amendment to the bill will allow for a possible exemption of producers that sell less than $500,000 a year, which covers most small organic farms. Still, the bill leaves questions unanswered.

Farmers like O’Brien are worried that the new standards will be required by wholesalers even of farms below the $500,000 mark, as well as those above. “It’s like entering a casino—there’s all these tables. If you certify you can play at any table; if you don’t, you can play at maybe three. Our wholesale buyers are requiring the certification on larger farms, so in turn, the wholesalers are requiring it from us.”

O’Brien also recognized the continually-shifting landscape of our knowledge about food safety and best practices. “We’re not working with a static medium here, and it deserves something more than a static approach, every day … We always want to look at life as if it’s something linear, and its not.”