By the end of 2010, the Food and Drug Administration (FDA) will issue a proposed rule to establish federal safety standards for the production and packing of fresh produce. The FDA has indicated their interest in hearing from the public about how this should be accomplished. The FDA will accept public comment through May 24, 2010. It’s easy and it’s important!
What you can do
1. Go to www.Regulations.gov.
2. Under “Keyword or ID” enter FDA-2010-N-0085-0001.
3. At the bottom, in the far right of the screen under Actions, click on “Submit a Comment.”
4. Fill out the requested information and type your comment into the field provided.
5. Press “Submit.”
What are the issues?
It is important that the FDA consider the size of a farm when making regulations. Small farms are not high-risk operations for food safety. They are our safety net against massive recalls. While all farmers need to understand and use good food safety practices, small farms should not be subject to unreasonable certification requirements (known as GAP) that could put them out of business because of the cost and time commitment. If this happens, the produce available to us will come from high-risk farms outside our local area.
What is the message we need to send?
Small farms (those earning less than $750,000) should not be required to become GAP certified, because the high cost and time commitment could put them out of business.
Small farms are not high-risk operations, and as such they should be required to have food safety education and minimal reporting requirements.
Small farms who sell food to restaurants, wholesale accounts, and directly to consumers should not be considered a food facility and thus should not have to abide by the food facility requirements of SB 510.
We need to protect and nurture those small farms that we can personally visit to see how they are handling their produce. Their trip from field to plate is short and direct and easy to trace. Their connections with their customers are personal and they care about the quality of what they produce. Keep them accountable to the people they serve through training and education but not through expensive certification.
Small farms are also careful stewards of the land, and that is an important part of our future. They respect and protect diversity, which are crucial to sustainable agriculture practices.
Submitting comments by mail
When submitting written comments, be sure to include the docket number at the top of each page. The docket number is FDA-2010-N-0085.
Mail comments to:
Division of Dockets Management
HFA-305
Food and Drug Administration
5630 Fishers Lane, Room 1061
Rockville, Maryland 20852
The comment period for this docket ends on May 24, 2010.