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

Provide options that treat family farms fairly, with due process and without excessive costs. Specifically, FDA must clearly define the “material conditions” that lead to a withdrawal of a farmer’s protected status in scientifically measurable terms. FDA must also outline a clear, fair, process for justifying the withdrawal of a farmer’s protected status and for how a farmer can regain that status.

Thank you for your consideration,


Another comment , from “Amy,” also talks of the over-regulation of the small producer.

I run a small farmers market in South Dakota. It is the only source for local foods year round. The community relies on the market and our small family farms rely on the market to make a living. We have spent years earning the trust, respect, and admiration of the community by providing a safe, clean market with reliable, trustworthy vendors. This rule will unduly harm our market and thousands like us. In fact, I fear it will force us to close leaving a huge gap for healthy local foods for consumers and subtracting a big source of income for small farmers. This country was on track to self-sustaining communities and food systems. That will all be for naught with this rule. Specifically, I am concerned:

They’re too expensive.

The rules could cost farmers over half of their profits and will keep beginners from starting to farm.

They treat farmers unfairly.

FDA is claiming broad authority to revoke small farmers’ protections without any proof of a public health threat.

They will reduce access to fresh, healthy food.

Local food distributors like food hubs could close, and new food businesses will not launch.

They make it harder for farms to diversify.

Grain, dairy, and livestock farmers could be denied access to emerging local food markets.

They will over-regulate local food.

The rules could consider farmers markets, roadside stands, and community-supported agriculture programs “manufacturing facilities” subject to additional regulation.

They treat pickles like a dangerous substance.

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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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