Comments Needed (by Nov. 15) on FDA rules

Dear Shared Harvest shareholders and all serious about sustaining our local, healthy food system,

Please pardon this unusual message, but I am joining the many farms and farming organizations that have realized the importance of taking action on this issue to preserve our growing small local food movement, the only hope we have for feeding ourselves and thriving into the future.  FDA food safety regulations in the works could cripple small farms like Picadilly, Riverland, and others, requiring unecessary expense and operational changes, some of which would threaten the integrity of ecological and organic growing systems these farms have worked so hard to set up and cultivate.  The regulations have been created based on science that is outdated and increasingly disproved, and with inadequate attention to the economic impacts on small farms that are not part of the food safety problem.

You may already be aware of this, as we are getting signals from many fronts, pretty much everyone concerned with supporting small farms, local food, organic practices, and community supported agriculture, that now is a very important time to raise our collective voices.  I’ve chosen the message I received from the Northeast Organic Farming Association (NOFA)– Mass to forward on to you, but they are just one of many organizations urging us to post comments.

In case it is easier for some of you, I will have copies of the consumer template available at this Saturday’s pickup in Canton and JP, which you can complete at the pickup and I”ll mail it, or you can take home and mail yourselves.   Completing it means adding your own comment, and signing with your name, city, state, and email address.  Of course you can complete, print, and mail your own from home, or post your comment online.  This issue is important enough to take a moment from our busy lives to give our input so that we don’t shoot ourselves in the foot by letting this happen to small farms.

Thank you so much for your ongoing support of small scale sustainable agriculture in our region and for your patience with yet another email in your inbox!

Jane

P.S. Also wanted to let you know that you can support this policy work by NOFA in another way, also, by donating to and cheering on the NOFA team running in the Genesis Battle Green 5k on Nov. 3. in Lexington. Donate here.

The comment period for the Food Safety and Modernization Act (FSMA) closes on November 15th. Some of the proposed regulations would make it very difficult for small farmers, and those choosing to eat food from small farms, to continue their current practices.
We encourage all NOFA/Mass members, consumers, and farmers alike to comment on the proposed FSMA regulations and how they would impact you. To make it easier, we have posted to our website template letters you can download and adjust.
  • Download the template letter for consumers here.
  • Download the template letter for farmers here.
As farmers, of course we all support food safety for ourselves, our families, our workers, and our customers. But NOFA/Mass feels that the draft regulations proposed by FDA ignore the most serious threats and in some cases focus needlessly on minutia. They need serious revision.
In several cases the FSMA requirements conflict with standards required under organic certification, and do not distinguish adequately between large farms with multiple sites and complex operations which entail greater risk and small farms which raise fewer crops, sell direct, and have a very short supply chain.
If you have questions, please contact Jack Kittredge, NOFA/Mass Policy Director, by email at jack@nofamass.org or phone at 978-355-2853.
Thank you for taking the time to learn more and act by November 15th on this important issue! 
 
 
Read this recent article for background on the draft regulations:

Food Safety Modernization Act

Sample Consumer Comment Template

 

Make Your Voice Heard: Submit a Comment to FDA Today!

The Food and Drug Administration will accept comments submitted online or through the mail. Use the sample comment below to get started! It is important to personalize your comment – FDA will read every single submission, and unique comments have the most impact.

Step 1 – Customize the comment below for yourself! There are guiding questions to help you tell your story effectively to FDA highlighted in yellow below.

Step 2 – Submit your comment in TWO places – to the Produce Rule (http://bit.ly/fsma-pr) and to the Preventive Controls Rule (http://bit.ly/fsma-pcr). This is important because these issues affect both rules. You can get extra help with instructions for using regulations.gov and for mailing a comment here: http://sustainableagriculture.net/fsma/speak-out-today/

Step 3 – Take a stand publicly and sign our FSMA petition! (http://sustainableagriculture.net/fsma)

 

Sample Comment for Consumers

[Remember – you’ll need to submit this online or mail in a hard copy to the destinations noted above.]

Re:  Preventive Controls Rule: FDA-2011-N-0920, Produce Standards Rule: FDA-2011-N-0921

I am a [concerned consumer, parent, entrepreneur, etc.] writing because I am concerned about the impact that FDA’s proposed FSMA rules will have on [the farms that I buy food from, my business, my family’s ability to find local food, the environment]. I ask you to ensure that new regulations do not put family farms out of business, harm farmers’ soil, water, and wildlife conservation efforts, or shut down the growth of local and regional healthy food systems!

[Customize your comment: Do you make an effort to buy from farms that use sustainable practices like organic?  Why? If local farms went out of business due to the rules, how would that limit your access to fresh produce? Why is it important to you that farmers be able to support habitat for honeybees and wildlife?]

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 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.

Thank you for your consideration,

[Full name, city and state, email address]

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