To see this action alert in your browser, click here.
Food Safety Modernization Act:
An Update and Call for New Comments
Farming is a challenging occupation. It takes ingenuity, intellect, and more than a little investment to make it as a family farmer in New England, and some of the most exciting innovations happening on farms today are related to farmers working together to get more fresh, healthy food into local markets, school, and grocery stores. In New England, we have made significant progress in diversifying our marketing avenues and in implementing farm to school programs—progress we do not want to see reversed by the proposed Food Safety and Modernization Act (FSMA).
As you may recall, last year we sent out an alert about new food safety regulations by the US Food and Drug Administration (FDA) and how they could make family farms, sustainable and organic agriculture, local food, and farm conservation efforts collateral damage. We have an update, and it’s both good news and bad news.
The good news is that the FDA received tens of thousands of comments from farmers and eaters alike—and they took those comments seriously, even agreeing to re-draft several key sections of the proposed FSMA rules. The bad news is that we’ve seen the new draft, and while they did make some critical improvements, the improvements don’t go far enough. What it comes down to is that the FDA still doesn’t quite get what it means to be a farmer. The last thing farmers and communities need is for their innovations to be unintentionally stifled by new food safety rules intended for corporate agribusiness, not family farms.
We need you to tell the FDA: Let our farm be a farm! The current proposed rules need to be modified to address the following three components:
· Farms innovate. Don’t let the rules suppress farmers’ innovative efforts in growing and selling local food. The rules need to ensure that local food and farms can grow and thrive, without burdening family farms that are scaling up, adding value to their products, or collaborating with other farm and food businesses.
· Farms work with nature. Don’t let the rules undermine farmers’ soil and water conservation practices by making it harder for farmers to protect wildlife and manage soil and water resources. The rules need to allow and encourage continued use of conservation practices on our farms.
· Farms deserve fair treatment. Don’t let the rules raise costs for farmers, food businesses, and consumers by imposing unclear, inconsistent, and unfair rules. The rules need to provide options that treat family farms fairly without unnecessary, excessive costs.
The time is NOW to speak out! Comments from farmers are the single most important way to fix the FSMA rules. The comment period ends December 15, 2014.
Farmers, we’ll be honest: commenting takes a little bit more time than signing a petition. But this is worth a few more minutes of your time, and we’ve developed materials to help you figure out whether you are affected by these rules; what FSMA means for your farm or business; and importantly, what should I say when I comment? NEFU has worked with the National Sustainable Agriculture Coalition to develop materials to help you understand how you will be affected and what you can do to take action. The information is compiled on this website.
Within the three components mentioned above (suppressing innovative efforts, undermining conservation practices, and raising costs), we have identified the following primary issues we need to address in this open commenting period:
· clarifying the definition of a farm and farming activities, and when a farm may be considered a facility, as well as farm ownership and the farm’s physical location;
· determining whether or not all food sales or only regulated food sales will be used to determine if a farm or facility is subject to the regulations;
· clarifying that CSAs, roadside stands, farmers’ markets, and other direct to consumer businesses are not considered facilities and therefore not subject to regulations for food facilities;
· aligning rules for using raw manure and compost with current best management practices;
· failing to promote on-farm conservation practices that support both food safety and protect our soil, water, and wildlife habitat;
· removing costly, unscientific standards for irrigation water, including overly burdensome water testing requirements that ask farmers to adhere to water quality standards designed for recreational purposes;
· ensuring the process for removing qualified exemptions, and reinstating such exemptions, is a clear, consistent, and fair;
· removing the supplier verification program for facilities, ensuring onsite audit requirements are not written in to the final rules;
· preventing the final rules from requiring costly environmental and product testing that will place excessive burdens on family farmers; and
· reducing paperwork and record-keeping requirements to fall in line with the ordinary course of business.
Everyone has a role in ensuring our nation’s food is safe – from the farmers who grow it to the folks who take it home and prepare it. But unless we act now, these new rules will have a devastating impact on the farmers and businesses responsible for putting fruits, vegetables, and other healthy foods on America’s dinner plates – which, in turn, affects our health and well being.
We have less than two weeks to be heard: COMMENT TODAY and help SPREAD THE WORD! The last day to submit comments is December 15, 2014!
If you’re ready to comment, submit them electronically here:
For detailed information and suggestions on the best way to comment, download this Word document for farmers, or this one for consumers.