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

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

The rules fail to protect a host of low-risk processing activities done by smaller farms and processors.

They make it nearly impossible to use natural fertilizers like manure and compost.

Farmers will be pushed to use chemicals instead of natural fertilizers.

They require excessive water testing on farms.

Farmers using water from streams and lakes will be required to pay for weekly water tests regardless of risk or cost.

They could harm wildlife and degrade our soil and water.

The rules could force farmers to halt safe practices that protect our natural resources and wildlife.

 

These critical comments of the FDA’s proposed rules come from the orientation of small farmers/farmers’ markets, but don’t think that large produce associations and big commercial growers will rubber stamp the FDA’s proposed food safety rules, either.

Water testing standards and the “one-size-fits-all” requirement for all covered produce trouble the industry, as do the exclusions and exemptions for smaller operations. Other issues in the produce rule include the definition of “farm” and “produce” (includes seeds and flowers?). For the preventive controls rule, industry groups are likely to say that mandatory testing of raw materials and finished product, mandatory environmental monitoring for pathogen and mandatory supplier approval and verification must go.

We’ll keep a close eye on the growing volume of comments to the FDA. Based on the record so far, the agency shouldn’t expect many ringing endorsements of their work.


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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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