Small farmers don’t much like the FDA’s proposed safety rule - The Packer

Small farmers don’t much like the FDA’s proposed safety rule

10/28/2013 10:31:00 AM
Tom Karst

Re: Preventive Controls Rule: FDA-2011-N-0920, Produce Standards Rule: FDA-2011-N-0921

I am a farmers market manager in a low-income neighborhood on the South Side of Chicago writing because I am concerned about the impact that FDA’s proposed FSMA rules will have on the ability of low-income communities served by farmers markets to continue to purchase fresh food. I ask you to ensure that new regulations do not put family farms out of business, harm farmers’ soil, water, and wildlife conservation efforts, or shut down the growth of local and regional healthy food systems!

If local farms went out of business due to the rules, it would severely limit underserved communities access to fresh foods. I manage the 61st Street Farmers Market in Chicago (Woodlawn community). Nearly 70% of low-income shoppers at the market that use an EBT/SNAP card purchase ALL of their fresh produce from local, family farmers at the market. Because the neighborhood is a food desert, there are no large grocery stores or other outlets to purchase fresh produce. If farmers are unable to come to market due to the proposed rules, residents will have no source of produce (and farmers no source of income).

I urge you to modify the rules so that they:

Allow farmers to use sustainable farming practices, including those already allowed and encouraged by existing federal organic standards and conservation programs. Specifically, FDA must not exceed the strict standards for the use of manure and compost used in certified organic production and regulated by the National Organic Program.

Ensure that diversified and innovative farms, particularly those pioneering models for increased access to healthy, local foods, continue to grow and thrive without being stifled. Specifically, FDA needs to clarify two key definitions: first, as Congress required, FDA must affirm that farmers markets, CSAs, roadside stands, and other direct-to-consumer vendors fall under the definition of a “retail food establishment” and are therefore not facilities subject to additional regulation. Second, FDA should adopt at least the $1,000,000 threshold for a very small business and base it on the value of ‘regulated product,’ not ‘all food,’ to ensure smaller farms and businesses (like food hubs) fall under the scale-appropriate requirements and aren’t subject to high cost, industrial-scale regulation.

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Jim Shiell    
Surrey, BC Canada  |  November, 04, 2013 at 11:54 AM

Hello Mr. Karst: As a former broiler chicken grower and now working in a regulatory position in the vegetable industry, I have experienced and observed the changes that occur when food safety regulations are upgraded. Canadian agricultural sectors have either completed upgrades similar to the FDA's rule changes several years ago or are in the process of completing the process in some smaller niche segments. Without exception, the comments you wrote of are similar or the same as has been expressed up here: "the extra work load is too great", "the additional costs are too high", or "I don't have time to complete the paperwork". I know because I've stated these arguments myself when we did this in the poultry sector more than a decade ago. In the end I observed that, if one sets up the paperwork /paper trail process on one's farm systematically and designs the farm's safety practices as part of the routine work schedule, no matter what type of agriculture one practices, one can actually use the papertrail as a checklist to enhance one's operation in food safe matters but also in ensuring that the daily, weekly, monthly, and/or yearly processes you take for granted are complete and there is little chance that you could be liable for not doing the "due diligence" if a food safety incident occurs. It also got me and my staff to take ownership of the food safe practices that were necessary to adopt. Once they were in place and practised regularly, there was little noticeable change in work load. Granted there is additional work up front when initiating the change(s), but one can design checklists and sign offs to be relatively painless and quick to complete once they become part of one's normal routine. Regards.

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