What follows below is an overview of the Food Safety Modernization Act- what congress passed left room for the small organic farmer.  The name seems harmless enough and our food should be safe, but there is so much more to it.  In the regulations the FDA is trying to implement All producers, both big and small are being lumped together an will have very expensive regulations saddled on their businesses.  There is a small farm exemption but what constitutes a small farm is very unclear and the FDA is given the authority to revoke a small farms exemption without any proof of a public health concern.  Once the exemption is revoked, the exemption is gone for good.  This huge expense placed on small farms will force many out of business- as stated by the FDA, a fact with which the agency seems to be unconcerned.  Loosing the small organic farmers from your local farmer’s markets will not make your food supply more safe- it will be devastating to your food supply.

In addition to all of this, most of the food contamination cases we have seen in the past have been traced back to the super large industrial farms shipping produce in from foreign countries including Mexico.  These safety regulations will not apply to them.  Therefore, those companies can offer cheap produce and food that is largely unchecked upon entry to our country and our local farmers will have to increase their prices to cover the cost of the regulations and unnecessary testing.  Therefore, the local small farmers will have an even harder time competing.

After reading the overview, please follow the link at the bottom to a site that will allow you to comment directly to the FDA with your concerns.  This site even has letters typed up that you can  copy and paste into the comment section at the FDA’s website.  It will take a bit of your time, but all of us have to stand up for our food supplies and the endangered species called the American small farmer.  Please help.  The comment deadline is November 15th.  We can change the fact that the law is in place at this time, but we can have a voice to make certain that the guidelines adopted are clear and helpful to the small farmers.

What is the Food Safety Modernization Act (FSMA)?

The Food Safety Modernization Act (FSMA) is the first major update of federal food safety laws since 1938. FSMA gives the Food and Drug Administration (FDA) broad new powers to prevent food safety problems, detect and respond to food safety issues, and improve the safety of imported foods. FSMA does not change food safety regulations for meat, poultry, and egg products, which are under the U.S. Department of Agriculture’s jurisdiction.

FSMA authorizes new regulations at the farm level for producers and certain facilities. Specifically, FSMA mandates the establishment of:

FSMA includes key provisions to make these new regulations scale-appropriate, conservation-friendly, and accessible to certified organic producers and value-added producers. The regulations focus on addressing food safety risks from microbial pathogen contamination (e.g., Salmonella, E. coli O157:H7, and Shigella). FSMA does not address food safety risks from genetically engineered crops, pesticide use, or antibiotic resistance.

FDA has released its proposed (draft) Produce Rule and Preventive Controls Rule and is seeking public comments on both! 

Why Does it Matter?

Everyone has a role in ensuring safe food from field to fork. The Food Safety Modernization Act (FSMA) includes new regulations of practices on produce farms and in facilities that process food for people to eat. This means it represents some big changes to our food system – and it is extremely important for the Food and Drug Administration to get these regulations right so that they improve food safety without placing an unfair burden on family farms.

The risk of foodborne illness — that is, the risk of getting sick or dying from food contaminated with pathogens like E. coli — is largely preventable by good food safety measures applied at every stage of the food supply chain. Examples of good measures include hand washing and keeping foods at the right temperature. However, it’s not as simple as requiring all farms and facilities to meet identical safety requirements. Depending on the complexity of the supply chain, types of food, and practices implemented from farm to table, different kinds of farms and facilities face different types of risks when it comes to contamination that could cause illness.

With the right approach, we will be able to help ensure good food safety practices across the nation without placing an unfair burden on family farmers.

Ultimately, we want to ensure a safe food supply, strong on-farm conservation of natural resources, and thriving family farms and small value-added farm and food businesses. With regulations and requirements that are tailored to different types and sizes of operations, we can achieve these objectives.

Where Did FSMA Come From?

Due to a rise in major outbreaks of foodborne illnesses and increasing bioterrorism concerns after 9/11, both Congress and the Administration proposed new food safety measures in 2009 that expanded food safety regulations to the farm level. Previously, food safety regulatory oversight was focused mainly on the processing, food handling, and manufacturing sectors – areas shown to be of highest risk for foodborne pathogen contamination.

In 2009 and 2010, Congress debated a number of food safety proposals that directly and indirectly affected farms and on-farm processing. These proposals extended regulatory authorities to farms and made some on-farm safety standards mandatory. Concurrently, the Obama Administration created an inter-agency Food Safety Working Group through which the Food and Drug Administration and the U.S. Department of Agriculture started adopting new food safety standards and oversight.

Given the potential impacts of these new food safety proposals on sustainable food production, NSAC created a task force and engaged in the legislative debate. NSAC’s priority was to make sure that the new food safety measures worked for sustainable and organic farmers, and for consumers who wanted access to fresh, local food. Due to NSAC’s leadership and the actions of thousands of farmers and concerned consumers, the new food safety law that Congress passed and that President Obama signed – the Food Safety Modernization Act (FSMA) – included the following critical provisions:

What Happens Next?

The Food and Drug Administration (FDA) has started the lengthy process of implementing the Food Safety Modernization Act (FSMA). FDA is currently in what is known as the rulemaking stage – meaning they are turning the bill – FSMA – passed by Congress into actual rules and regulations. They have released their proposed (draft) regulations for public comment as part of this process. These proposed regulations show FDA’s thinking on how to implement the provisions in FSMA and are not yet final. Currently, FDA is requesting comments on two proposed regulations:

After FDA has received and reviewed the comments, the agency will prepare to publish final rules (with rules as big as these, the agency might opt to release another draft set of rules before finalizing them). All of the positive provisions listed above that Congress passed as part of FSMA must make it into the final rules published by FDA to become part of the new regulations.

NSAC is carefully analyzing the proposed rules to ensure this happens, and we need your help – it is critical for sustainable farmers and consumers who care about where their food comes from to write comments to FDA about the proposed regulations to ensure that FDA correctly implements FSMA! Check out the links below to learn more about the two rules – and then submit your own comments to FDA!

 

Click HERE for the page to enable you to leave your comment with the FDA.  There is a button for producers and a button for consumers.

Thank you for you time.

Just another note- the FDA that is charged with inspection, regulation, and enforcing the exemption rule is staffed with many big Monsanto boys appointed by the President- going back several terms.  Is it any wonder that this act is damaging to small farmers?  Monsanto has been suing and bulling small farmers for years and putting them out of business.

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