[This alert is over–comment period now closed]
Food Safety Modernization Act: New Draft Rules
Comments Due on December 15 to FDA
Please take action by reading the full Action Alert available on the Cornucopia website: http://www.cornucopia.org/food-safety/
Although improved over the first draft the FDA’s proposed food safety rules are still onerous enough that they could jeopardize the existence of many of our safest, local organic farms.
Tell the FDA that small farms are not food processing “facilities” necessitating expensive oversight and testing. (It could cost a family farm over $12,000 a year to comply!). Irrigation water should not have to meet the same safety standards as a community swimming pool. And it should be clear that older farmers, without Internet access, or the Amish, can submit reports on paper rather than the web.
At a minimum, please join farmers and their urban-allies by signing on to the letter below. Additionally, we especially encourage fresh market vegetable farmers to also, very carefully, read the full action alert and submit your individual comments, based on your own farming experience, to the FDA. Your livelihoods are at stake.
RE: FSMA Food Safety Rules, Dockets FDA-2011-N-0921-0973 and FDA-2011-N-0920-1553
We the undersigned are concerned by several areas of the FDA’s revised food safety rules and endorse the following comments.
- The cost to farmers for implementing the proposed rules will endanger the livelihoods of organic farmers and their customers’ access to safe and nutritionally superior local and organic food. This regulatory burden, as much as $12,384 for farms with sales of $500,000 or less, is an unacceptable imposition of financial hardship on producers with no history of food safety problems.
- Farms are not facilities. Growing, harvesting, packing, or holding raw agricultural commodities are clearly part of many farm activities. Furthermore, the regulations should allow for non-contiguous farm parcel locations to be treated as one farm and not discriminate against cooperatives or food hubs.
- The FDA must clarify that CSAs and direct market farmers are not facilities.
- The proposed use of the EPA’s recreational water standard is an inappropriate and overly restrictive measure for testing the safety of irrigation water. Before establishing a numeric testing standard for the safety of irrigation water, the FDA must conduct a risk assessment for water used specifically for agricultural purposes, and follow the instructions from Congress that a science and risk-based approach be used for regulation.
- Recordkeeping requirements should be reasonable, limited to one year, and allow for paper records.
- The FDA must establish a fair process for any enforcement actions against farmers that allows due process, full documentation of any alleged food safety issues, and the opportunity for a hearing to contest erroneous information.
- The FDA must respect the exemption from the food safety rules for smaller farms, as guaranteed by the Tester-Hagan amendment. That exemption must be determined by the level of sales of produce covered by the rule, not the total sale of all food grown and raised on a farm.
- On-farm conservation practices need explicit support in the food safety rules. The grazing of livestock must not be considered manure application.
- The FDA’s proposed changes made to the manure handling regulations are a needed improvement. The study committee that will be established to assess the risks of manure usage must include sustainable and organic farmers.
- The FDA should remove the supplier verification program from the Hazard Analysis and Risk-Based Preventive Control (HARPC) food safety rule. This backdoor approach would allow for large produce buyers to impose more stringent and costly food safety regulations than outlined in the FDA’s proposed rules.
- The FDA’s new definition of a small business is an improvement over previous proposals.
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Thank you for your help!
If you are interested in doing even more, please read the full action alert below: Read Full Article »