Food Safety Modernization Act – Why You Should Comment

Recently, Countryside Conservancy submitted our comments to the FDA regarding the proposed regulations in the Food Safety Modernization Act (FSMA).  We are currently in an open comment period, ending November 15.  Please read our statement below and consider adding your voice to support small farms.  Click here to visit the National Sustainable Agriculture Coalition’s (NSAC) website and learn more about the proposed regulations and submitting your comment.  For ideas on what to say, view these two documents, courtesy of the NSAC:  FSMA_Sample_Consumer_Comment_Template or NSAC_FSMA_Sample_Farmer_Comment_Template.

 

The purpose of Countryside Conservancy is to connect people, food, and land.  We support and engage countless small farmers throughout the region in our programming work of Countryside Farmers’ Markets, Countryside Initiative, and Countryside U.  And while we feel strongly that food safety is a crucial component of a sustainable food culture, the proposed regulations of the Food Safety Modernization Act (FSMA) will ultimately harm our local food systems, degrade the quality of life of those who value locally grown and sustainably produced foods, and may result in the failure of thousands of farms and related agriculture and food businesses in our state, having a substantial impact on Ohio’s economy.

Our specific concerns are the extreme expense to small growers, unclear standards and procedures for exemptions, and the lack of consideration for organic and sustainable management standards.

The majority of farms we assist and advocate for fall into the FDA categories of “small” and “very small.”  The cost estimates for compliance of these regulations, as projected by the FDA, would be devastating for farms in these categories.  Projections indicate these farms could lose anywhere from half to more than 100% of profits in the first year of compliance, with future years looking equally grim.  If these regulations are put into effect, we recommend the FDA or USDA subsidize the cost of compliance for the protection of the family farm.

In the proposed regulations, the smallest farms (making less than $25,000) will be exempt from compliance, while others fall under a modified requirement status.  There remains great uncertainty around these statuses – particularly surrounding the withdrawal of exemption and restitution procedures.  Clarity is needed before any regulations are passed.

Finally, the current proposed regulations do not adhere to the National Organic Standards.  Small farms practicing organic or sustainable management do not have the land or length of growing season to adhere to the FSMA, nor do we believe the regulations are sound given our decades of experience with organic and sustainable production.  We recommend a reconsideration of this portion of the FSMA with close consultation with agricultural experts in organic and sustainable production methods.

We believe the FSMA regulations were not written with consideration of small and very small farms.  Our constituency cares deeply about food safety, but we believe very few would support the current FSMA.  We also believe the FSMA’s “one size fits all” approach to food safety will be ineffective and potentially devastating to our local food systems.

We ask that in your efforts to do your due diligence you avoid creating another food safety hazard: an America without small, family farms and food businesses.

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