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.