From: Mark Schonbeck [mailto:firstname.lastname@example.org] Sent: Saturday, April 13, 2013 10:04 PM Subject: organizational comments on Food Safety proposed rules Importance: High
I am contacting you with some preliminary information on the FDA's Food Safety Modernization Act (FSMA) proposed rule, for which the public comment period closes May 16. In addition to individual comments, the National Sustainable Agriculture Coalition (NSAC) is seeking organizations to submit comments - including sustainable / organic agriculture non-profits, food hubs, community food system advocacy groups, etc. I immediately thought of Appalachian Sustainable Development, since you work with at least 60 farmers in southwest Virginia to market organic produce, pasture-based eggs, and other farm products. Both the Produce Rule for farms and the Preventive Controls Rule for food processing and handling facilities can potentially impact your work and the livelihoods of your farmers and food system workers.
When Congress passed FSMA, it was written in such a way that mandated food safety regulations that are scale appropriate and compatible with conservation and sustainable ag and food systems. The NSAC Food Systems Integrity Committee has worked hard to analyze the 1,700 pages of text in the Proposed Rules, to determine whether they meet the Congressional mandate and protect the livelihoods of family farms, and where they fall short. The Committee is in the final stage of developing talking points and additional information to help farmers, other concerned citizens, and non-profit organizational representatives develop comments.
A number of significant concerns have been identified with the Proposed Rule. The NSAC committee is in the process of developing detailed information on these and posting them on an informational web site. Following is an excerpt of a message from NSAC Grassroots Coordinator Sarah Hackney, including the link to the web site:
"With the deadline for comment on the Food and Drug Administration’s (FDA) proposed food safety regulations fast approaching (May 16), NSAC has launched a new food safety website with resources for farmers, on-farm processors, and consumers. It includes basic information about the bill and guidance for farmers and processors to help them determine if they might be impacted by the new rules. We will be updating the site over the next week with more substantive information about key issues with FSMA. We are ramping up for a major grassroots outreach push to generate comments into FDA on these rules - starting next week. This will be an all hands on deck action - so check out the site now and get ready!" http://sustainableagriculture.net/fsma/ included is a bulk e-mail message on the issue that will be sent out at the beginning of next week Sincerely, Mark Schonbeck 540-745-4130
FDA Proposed Rules for the Food Safety Modernization Act Public comment period closes May 16
In January, the US Food and Drug Administration (FDA) published two Proposed Rules as mandated by the Food Safety Modernization Act (FSMA) passed by Congress and signed into law by the President in 2011. The Produce Rule covers on-farm food safety practices related to fruits and vegetables, and the Preventive Controls Rule covers practices in food processing facilities.
The FSMA instructs FDA to develop regulations that would substantially reduce risk of foodborne illness from fresh produce and other foods, without creating undue burdens (exessive costs, unnecessarily complicated record keeping procedures) on smaller farms and food businesses. The regulations must also be compatible with good conservation practices and with the USDA National Organic Program. Most important, the rule must be "scale appropriate" and appropriate to the kind of operation - no "one-size-fits-all" industrial model regs.
Since the Rules were published, a team of sustainable agriculture advocates and analysts, coordinated through the Food Systems Integrity Committee (FSI) of the National Sustainable Agriculture Coalition (NSAC) have been working diligently to evaluate the Proposed Rules (which come to some 1,700 pages), and determine whether they actually meet the requirements of the original Act and allow family farms, local food businesses, and organic farmers to thrive while helping them maximize the safety of their products. A number of issues have emerged through this analysis, including some areas of ambiguity (some of which FDA itself is requesting input from stakeholders), and others that definitely raise red flags.
Over the next few weeks - between now and the close of the comment period, we will need as many farmers, food entrepreneurs, and sustainable agriculture and local food organizations as possible to submit their comments regarding how the proposed rule will affect them and their businesses, and how it must be modified to protect their livelihoods.
The NSAC FSI committee is in the final stages of writing up their analysis and key talking points to help you write your comments. NSAC has launched a web site with in-depth information about the FSMA. It is now live at http://sustainableagriculture.net/fsma. Stay tuned to additional developments related to the Proposed Rule by visiting this web site periodically.
Note that this web site is still "in process" and more and more content will be added to provide more information on key issues related to the Rule, and guidance for developing your comments.
One thing that most of you will want to know ASAP is "am I affected by the new Food SAfety Rules?" The FSMA includes provisions, offered by Senator Jon Tester of Montana (who is an organic farmer), to provide less-burdensome alternative food safety procedures ("exemptions") for small farms and small food businesses (gross proceeds under $500,000 annually); the Propused Rule reflects these provisions. To find out how the proposed Rule might affect your farming or food business, visit http://sustainableagriculture.net/fsma/who-is-affected/