Current Action Alerts

Food Safety Petition and Action Alert

Friday, December 5th, 2014

[This alert is over–comment period now closed]

Food Safety Modernization Act: New Draft Rules
Comments Due on December 15 to FDA

FDA3Please take action by reading the full Action Alert available on the Cornucopia website:

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.

TO: The Food and Drug Administration
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.

* denotes a require field

Thank you for your help! 

If you are interested in doing even more, please read the full action alert below: Read Full Article »

Action Alert — Food Safety Modernization Act: New Draft Rules Comments Due on December 15

Friday, December 5th, 2014

FDA3[This alert is over–comment period now closed]

In response to recent widespread, and sometimes deadly, outbreaks of foodborne illness, Congress passed the Food Safety Modernization Act (FSMA) charging the Food and Drug Administration (FDA) with improving their oversight of the food industry.

But the intense blowback the FDA received last year from family-scale farmers and consumers over their proposed food safety rules for produce led the agency to withdraw and rewrite their proposed rules. Your comments last year had an impact!

The FDA has now released their new draft, which addresses many of the objections. However, a number of problems and pitfalls for farmers remain in the new draft. The proposal will also be of interest to the customers of local, organic food purchased through farmers markets, CSAs and co-op grocers.

Public comments are due by December 15 on the draft rules.

The Cornucopia Institute, working with other groups, has requested a 90-day extension to allow for fuller and careful analysis of the latest proposal.

You can comment online, but be sure to do so at both of these locations as the regulations impacting family scale farmers are intertwined in both of these FDA dockets:!submitComment;D=FDA-2011-N-0921-0973!submitComment;D=FDA-2011-N-0920-1553

Or you can comment by mail to Division of Dockets Management (HFA-305), Food and Drug Administration, 5630 Fishers Lane, Rm. 1061, Rockville, MD 20852. Make sure you note that you are commenting on dockets FDA-2011-N-0921-0973 and FDA-2011-N-0920-1553. Your letter needs to be postmarked no later than December 15.

According to the analysis performed by the National Sustainable Agriculture Coalition, growers with sales up to $500,000 would likely spend 4% to 6% of their gross revenue to comply with the new food safety rules.  For small farms, FSMA could consume more than half of their modest profits. It is important that family-scale farmers producing our nation’s fda2best and safest produce be protected from unnecessary and onerous regulations — this could put some farmers out of business and/or reduce the availability of organic and local food and/or increase pricing.

Key Points to Mention in Your Comments:

  • Tell the FDA that 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.

Read Full Article »

EPA Accepting Comments on Pollinator Health Until November 24, 2014

Wednesday, November 19th, 2014

Beyond Pesticides

Co-Chairs of Pollinator Health Task Force:
USDA’s Tom Vilsack and EPA’s Lisa Jackson
Image Source: USDA

At the close of Pollinator Week 2014 President Obama called on government agencies to create a plan to “promote the health of honey bees and other pollinators.” However, at the end of last month the Task Force announced it would miss its self-imposed December 20th deadline on its action plan, delaying needed steps towards improving pollinator health.

EPA will be accepting written comments at this link until November 24, 2014.

Talking Points for Comments:

EPA and USDA have a duty to protect our nation’s pollinators, and the Presidential memorandum has directed federal agencies to take action. Given average loss rates near 30% over the past 8 years, there is an urgent need to move quickly on finding long-term sustainable solutions for pollinator protection. A growing body of scientific evidence reveals connections between pollinator declines and pesticide exposure, making it evident to the public and government agencies that action must be taken to rein in these harmful chemicals. Read Full Article »

Living With GMOs

Wednesday, November 12th, 2014

The Letter From America

letter-from-americaAn open letter to the citizens, politicians, and regulators of the UK and the rest of the EU about the hazards of genetically modified crops

We are writing as concerned American citizens to share with you our experience of genetically modified (GM) crops and the resulting damage to our agricultural system and adulteration of our food supply.

In our country, GM crops account for about half of harvested cropland. Around 94% of the soy, 93% of corn (maize) and 96% of cotton grown is GM.1

The UK and the rest of the EU have yet to adopt GM crops in the way that we have, but you are currently under tremendous pressure from governments, biotech lobbyists, and large corporations to adopt what we now regard as a failing agricultural technology.

Polls consistently show that 72% of Americans do not want to eat GM foods and over 90% of Americans believe GM foods should be labeled.2 In spite of this massive public mandate, efforts to get our federal3 and state4  governments to better regulate, or simply label, GMOs are being undermined by large biotech and food corporations with unlimited budgets5 and undue influence. Read Full Article »

WHITE HOUSE PETITION: President Obama, Please Reverse USDA Coup Undermining Organics

Wednesday, July 16th, 2014

[This petition is now closed]

WHITE HOUSE PETITION: Ask President Obama to Reverse USDA Coup Undermining Organic Governing Board and Shifting Power to Agribusiness Lobbyists

Stop allowing corporations to add gimmicky and risky synthetic chemicals to organics

sign petition button

When Congress passed the Organic Foods Production Act of 1990 (OFPA), they created a unique and powerful citizen advisory panel, with statutory authority, to assist the Secretary of Agriculture in implementing the act.   The independent National Organic Standards Board (NOSB) was a key component of OFPA when it passed Congress.  Without its creation as a buffer between corporate lobbyists and an industry-friendly USDA (the agency testified against the organic legislation before its passage), it is unlikely that OFPA would have received the requisite support in the organic farming community.

Now the independence and power of the 15-member NOSB – composed of farmers, environmentalists, public interest groups, food processors, a scientist, a retailer and a certifier – is being seriously undermined.  Last fall the USDA, in its most unapologetic and undemocratic power grab to date, broke with 15 years of precedent in stripping the NOSB of much of its authority and power.

Please help roll back these changes by signing this petition
to President Obama and USDA Secretary Vilsack. Read Full Article »

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