Below is the submission I made last Friday (the prior deadline) for public comments on the FDA’s proposed new farm/food regulations due to the 2011 legislation know as the Food Safety Modernization Act. However the deadline has been extended to this coming Friday, November 22nd. Be sure to file your own comments both here and here! We need to take control of our own food systems! – Jack
To FDA, I am a concerned citizen and strong supporter of my local community markets and farmers. We buy as much of our food from local producers as we possibly can, and prefer those that are organically certified or at least follow organic practices. These proposed rules scare me silly. It appears they are likely to devastate those businesses and the small farmers everywhere who work so hard to provide healthy and fresh food to us.
Specifically, I am worried about:
The manure and compost rules which clearly are in conflict with the current USDA organic standards.
The definition of small farms and how they qualify for exemptions. Using dollars of revenue threshold on all food is too broad and, for certain if you use a dollar amount, then it needs to be indexed to future FOOD prices such that farmers are not forced into the higher category in the future by the continuous march of inflation, labor & energy prices.
The impact of these standards on Aquaponic methods, systems and farmers. This innovative technology is capable of providing local produce and fresh fish from urban (as well as rural) farms with much lower use of potable water. Yet these standards would seem to prohibit it.
The failure of these rules to consider the relative dangers of other farming practices, specifically GMOs, pesticides, chemical fertilizers, and other high energy processes and their impacts (e.g. carbon emissions, dust, soil depletion, water pollution & consumption, allergies, etc) on the health and safety of both the public, farm workers and on the natural environment.
I urge you to modify the rules so that they:
Allow farmers to use sustainable farming practices, including those already allowed and encouraged by existing federal organic standards and conservation programs. Specifically, FDA must not exceed the strict standards for the use of manure and compost used in certified organic production and regulated by the National Organic Program.
Ensure that diversified and innovative farms, particularly those pioneering models for increased access to healthy, local foods, continue to grow and thrive without being stifled. Specifically, FDA needs to clarify two key definitions: first, as Congress required, FDA must affirm that farmers markets, CSAs, roadside stands, and other direct-to-consumer vendors fall under the definition of a “retail food establishment” and are therefore not facilities subject to additional regulation. Second, FDA should adopt at least the $1,000,000 threshold for a very small business and base it on the value of ‘regulated product,’ not ‘all food,’ to ensure smaller farms and businesses (like food hubs) fall under the scale-appropriate requirements and aren’t subject to high cost, industrial-scale regulation.
Provide options that treat family farms fairly, with due process and without excessive costs. Specifically, FDA must clearly define the “material conditions” that lead to a withdrawal of a farmer’s protected status in scientifically measurable terms. FDA must also outline a clear, fair, process for justifying the withdrawal of a farmer’s protected status and for how a farmer can regain that status.
Please reconsider, in better collaboration with the USDA organic standards, and reissue these regulations.