In support of the Food Safety Modernization Act, the FDA is creating new rules which threaten small farms, sustainable and organic agriculture and farm conservation efforts and the environment. According to the National Sustainable Agriculture Coalition (NSAC), the new rules as currently written will “put many farms out of business, reduce the supply of fresh, local produce in schools and hospitals, push farmers to tear out wildlife habitat, and increase the use of chemicals rather than natural fertilizers.”
A comment period is open until November 15, and it’s important that we speak out to support the farms that supply the food we enjoy so much and that make this area of the country so agriculturally vibrant. (Despite the government shutdown, comments are still accepted on the FDA website.)
Using a template provided by the NSAC, I wrote my own customized comment to submit. You can find more information on the proposed rules, as well as instructions for how to submit your comment on this special website.
Feel free to copy my comment that appears below or write your own – but either way, speak up. Every voice matters – and if you’ve enjoyed a CSA this season, part of that “community support” is to stand beside farmers and to do what’s right for them and our community and environment.
Follow NSAC on Twitter at @sustainableag for the latest updates – spread the word!
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 where I source my food, as well as the environment and my local economy. 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!
My family subscribes to community supported agriculture programs from local farms, which enables us to have access to the freshest, healthiest produce, grown without practices that harm farm workers or the environment. These small businesses are not just an asset to our local economy, but an asset to the health and well being of our community members. Many local farms donate produce to needy families or offer reduced price shares and give back to the community that supports them in many ways. They also allow us to purchase healthy food without the extra markup from conventional stores, adding an economic benefit – the money stays entirely in our community instead of benefiting out of state or out of country corporations. These farms are in indispensable part of our region and my own life.
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.