As 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 www.regulations.gov 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.
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: