The following is the email I recieved from the farmers with whom my family and I participate in a CSA. They are our farmers, our friends, and our neighbors. To all of you who are my friends, family, and acquaintances I implore you to please please PLEASE read the following and follow the directions as to how to respond to the FDA. This is not some silly Facebook please repost foolishness this is a very real and potentially devastating change in my families, friends, communities lives that you can help avert. Please help. Thank you. Dear Shareholders, I’m a little preoccupied this week by the Food Safety Modernization Act. This is a law passed by Congress requiring the Food and Drug Administration to regulate farm production and handling of fresh produce, with the goal of reducing risk of harmful microbes entering and spreading through our food supply via fresh produce. The actual regulations are still being drafted and reviewed by FDA and the public. So I’m preoccupied for several reasons. The legislation as written now will have significant impact on our farm: financially, ecologically and time-wise. Picadilly Farm is just big enough to be required to comply with all of the rules of the act – putting us in the same compliance category as the biggest commodity, wholesale farms in the nation. FDA itself estimates that adherence to the regulations will cost a farm of our size $43,000 annually, (after significant initial infrastructural changes to our washbarn). This is an impact I am not at all certain that we could absorb and remain successfully, viably, and enjoyably in business. Of course, Bruce and I are concerned about the safety and health of our food! Our livelihoods have been built around producing high quality, clean food for our own family, our neighbors, and our shareholders. I’m all for improvements that will make a difference, but the regulations are unlikely, in my opinion, to positively impact the safety of the food grown on and distributed from our farm. Hmmm. This is relevant now because FDA is accepting public comments on the proposed rule through this Friday, November 15. I’ve read about the rules, attended an FDA hearing up in Hanover in August, and am preparing my final comments for submitting. I will post my comments on our website once I’ve submitted them. I’m asking you to take a few minutes, by Friday, to read about FSMA, and to submit online comments about the proposed rules. At the bottom of this newsletter, I’ve pasted in a link to information about FMSA, and details about commenting to FDA, including the internet links and a draft letter. I know life is busy, and demands for our attention are many. For these regulations, which are still being written, there is good reason to believe that our collective voice will be heard, and the rules will be significantly modified. Public comments played a significant role in shaping the National Organic Standards in the 1990’s, when big agribusiness was working hard to sway the agenda in their favor. For the sake of our farm, our livelihoods, and our flourishing regional food system here in New England, we’d like a common sense and science-based approach to prevail. Your comments to FDA can help make a difference, and Bruce and I will personally appreciate your effort. As always, please talk with us if you have questions or expertise to share. A straightforward summary of FMSA is here, written by Brattleboro UVM agricultural extension agent Vern Grubinger. Reading time is about 10 minutes. uvm.edu/vtvegandberry/factsheets/Understanding_FSMA_Rule.pdf To make a comment to FDA: 1. Submit it in two places, as there are two parts to the FSMA 2. Individualize your note a bit, so FDA will accept it as an original comment, not a duplicate. 3. Submit online (rather than by mail), in order to meet the Nov 15 deadline SAMPLE LETTER Here is a sample letter, from CISA in Massachusetts, which I have amended very slightly for your use. Know that to be counted as a distinct comment, you must edit this at least slightly – add in your name, that you are a CSA shareholder, change or delete a few sentences. buylocalfood.org/sample-letter-to-the-fda/ I have profound concerns about these rules with regard to their impact on local farms and on my ability to continue to purchase produce grown by the farmers in my community. As a consumer strongly committed to the health and safety of our local food system, I am deeply concerned that the proposed rules will disproportionately harm the small farms in our region by burdening them with new financial and time demands that they simply cannot afford to meet. The research behind these rules is sorely lacking – especially with regard to practices on small farms – and the costs of the rules for local farms are far too great to justify the highly questionable benefits. I support federal efforts to reduce food borne illness originating with large-scale industrial farms and food businesses. Indeed, in an era when our food system is highly consolidated and dominated by a small number of multistate and multinational corporations, the FDA must have authority to enforce basic food safety standards across state lines and issue recalls when necessary. However, if these rules drive small-scale local farms out of business – as the FDA’s own analysis indicates they will – I strongly believe this will not improve the safety of our food supply. Small farms allow for a shorter supply chain from farm to consumer, so the source of any outbreak is easy to trace, and customers and businesses can quickly respond. Local food systems are thus able to correct food safety threats far more rapidly than large-scale industrialized food systems, which rely on complex traceability requirements and federal oversight. My specific requests to the FDA are as follows: 1. You must change the rules so they don’t disproportionately burden small farms – The overwhelming majority of food borne illnesses originate in food handling practices after food leaves the farm, or on the very large farms that dominate our food system – NOT on small farms that market locally. As Congress mandated, the rules already include limited exemptions for farms with gross food sales below $500,000. These exemptions are crucial, but both rules can and should go further. Many small local farms gross over $500,000 (netting a tiny fraction of that), while still posing low risk to consumers due to a short supply chain and the ease of tracing products back to the farm. Congress authorizes the FDA to exempt or modify the requirements for small farms that are low risk. 2. You must remove restrictive requirements from the rules that are not justified by existing science and are inappropriate or impractical for local farms. The nine-month waiting period between manure application and harvest more than doubles the waiting period that is currently recommended as the “best practice” in our region. The field research supporting a nine-month waiting period does not exist, and the economic and environmental impacts are untenable. Similarly, water testing requirements and water standards are based on inadequate research and would unacceptably burden small local farms. 3. You must change the rules so they support sustainable farming practices and do not negatively impact the environment. You must incorporate the conclusions from your pending environmental impact analysis into the final rules. Specifically, the rules must change so they do not put small sustainable farms out of business, or create new incentive for farmers to remove wildlife habitat around their farms, pollute waterways by stockpiling manure, implement widespread chemical treatment of water, or stop producing and applying compost. 4. You must add to the rules a process for protecting the exempt status of small farms not covered by the rule, and a process for reinstating exemptions that are removed by the FDA. As written, the rule gives the FDA broad powers to remove small farms’ exempt status without due process. Before removing the exempt status of a farm, the FDA should be required to give the farm a “warning letter” so that the farm has an opportunity to fix the identified issues. In order to remove a farm’s exemption, the FDA should be required to justify, with specific scientific information, why the farm’s practices pose unacceptable risk of a food borne illness outbreak. A farm must then an opportunity to appeal the FDA’s decision to remove its exemption, as well as to take steps to reinstate its exempt status. 5. The final rules must allow for alternatives appropriate for small farms. Local farms lack the resources to establish alternatives to these one-size-fits-all rules, even when the rules permit this. Either the FDA should fund the necessary research for small farms to establish alternative means of compliance that are consistent with local farming practices, or existing state-based food safety programs be accepted as a means of complying with the rule. 6. You must change the rules so that they don’t prevent farmers from working together to efficiently bring their produce to local markets to meet the growing demand for local food. As written, farmers handling even a minimal amount of produce from their neighbors face a much higher regulatory burden. As Congress intended, CSA farms that occasionally aggregate produce from other farms should not fall under the definition of a facility under the Preventive Control Rules. Thank you for your time and consideration.
Posted on: Sat, 09 Nov 2013 15:47:35 +0000
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