The Food Safety Modernization Act:  Comments Due TODAY!

The Food Safety Modernization Act (FSMA) is the first major overhaul of our nation’s food safety practices since 1938.  It includes new regulations for farms and for facilities that process food for people to eat. 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.

Why Does it Matter? 

Done right, these new rules can help make our food safer; done wrong, they run the risk of putting farmers out of business, limit consumer choice, and increase the use of chemicals rather than natural fertilizers, among other problems.

Round Two: 

Last year tens of thousands of comments were submitted on the first draft and comment period. This is the second comment period and it closes on Monday December 15. Last year’s comments are responsible for some improved parts of the draft and FDA announced that it would reexamine several critical areas of the FSMA proposed rules that have major potential impacts for sustainable farming.

FSMA does not address food safety risks from genetically engineered crops, pesticide use, or antibiotic resistance.  Specifically, FSMA requires FDA to establish new regulations for:   Standards for produce production (Produce Rule), and food safety measures for facilities that process food for human consumption (Preventive Controls Rule).

Specific points:

Local and Regional Food Systems -  The rules need to support and encourage innovation that helps people and farmers, not stifle it – local and regional-scale efforts like cooperative CSAs that help farmers meet demand and access new markets shouldn’t be subject to standards intended for large industrial operations.

Farmers - The rules need to support farmers rather than putting them and their farms at risk. The barriers to entry for new farmers will grow in complexity and expense.

Small Business and Local Economies -  The costs of complying with these rules could put small-scale enterprises out of business and stifle job creation.

Conservation and Sustainability -  The rules need to explicitly encourage key conservation practices – like maintaining wildlife habitat or stream buffers along waterways – that science shows are good for the environment and for food safety.

Farm to School – The rules could make it harder for children and schools to get fresh, healthy produce – many of the tools that farmers and community enterprises use to get fresh produce into schools, like aggregating or doing light processing, could be subject to expensive, burdensome facility requirements that prevent them from operating.
Food Access and Public Health - The rules will could make it harder to combat our epidemics of diabetes, obesity, and heart disease, and could make our public health worse – we need more access to fresh, healthy food – not less!

Organics -  FDA’s revised approach to compost and manure could mean a big win for organic farmers – but we need to make sure FDA follows through on these changes, and involves the sustainable and organic farming and research community in its research on this issue.  

For full analysis of the regulations and other information go to NSAC’s FSMA Website.