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

Tom KarstAs of Oct. 28, the FDA has received 2,349 comments on the “produce safety rule.” Just think how many thousands more will arrive before the deadline on Nov. 15!

Check out the docket for the proposed rule on the website here.

 Generally, we can expect that some of the industry heavy hitters will file comments closer to the deadline, but that is not to say that we have not seen some thoughtful comments on the rule so far.

Filing a comment in late October, “Elizabeth” writes about the produce rule and the preventive control rule from the perspective of a farming operation in Oregon,

Since my family operates a small farm and my daughter is in the process of beginning a larger farm in Oregon, we are aware of the problems created if the Food Safety Modernization Act does not consider how it might negatively impact small farms without positively affecting food safety.

We are able to operate in a clean and reliable manner because we are able to give attention to detail. Our friend told us about on her small farm where my daughter interned that her milk pus counts were far below typical numbers. We consume our own products and we want safe, healthy food.

HOWEVER, we need to achieve quality food without bearing expenses that would put us out of business as we scarcely can make a living already with food prices being so low for the producer.

Both Rules. The cost of compliance needs to be kept to a minimum and FDA needs to provide free training to very small producers.

Produce Rule.

E coli is not an appropriate measure of water borne illness as it has various strains and other organisms such as Salmonella are not necessarily associated with it. Weekly water tests are too expensive for the smaller operations and unnecessary.

Manure applications should not be treated like other soil amendments nor should rules interfere with conservation practices.

Manure and compost applications do not need to be separated from harvest time by more than the National Organic Program requires.


Also writing in late October, “Danny” says the FDA rules shouldn’t drive small producers out of business, but may have that effect. From his comment:

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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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