[Market-farming] Market-farming Digest, Vol 122, Issue 21

Steve Gilman stevegilman at verizon.net
Mon Mar 25 17:36:41 EDT 2013

Just a word on FSMA. The proposed produce rules are in the active Comment phase until May 16th. Materials to help citizens comment on aspects of FSMA will be available soon via a website. After May, FDA will write the final regulations, taking into account the comments -- so what we see now is not necessarily what we'll get. 

And even if the Tester "exemptions" make it through the rule-making process intact -- under Tester's alternative pathway farmers are beholden to state and local health and ag rules, while the overarching Food, Drug and Cosmetic Act makes it illegal to sell "adulterated" (contaminated) food. 

Further, under the "material exemptions" clause in FSMA farmers are liable at any time for FDA inspection, action and loss of exemption if an outbreak is traced to their farm.

Avoiding risky procedures is always the best policy.

Steve Gilman

On Mar 25, 2013, at 4:32 PM, market-farming-request at lists.ibiblio.org wrote:

> Message: 4
> Date: Mon, 25 Mar 2013 15:10:25 -0400 (EDT)
> From: Kakerby <kakerby at aol.com>
> Subject: Re: [Market-farming] foliar sprays
> To: market-farming at lists.ibiblio.org
> Message-ID: <8CFF7A38A22726F-1820-53A7 at webmail-d127.sysops.aol.com>
> Content-Type: text/plain; charset="us-ascii"
> Excellent point; even if a farm doesn't already come under FSMA rules, risky procedures will land it there anyway.  Thanks for that reminder, Rivka.
> Kathryn Kerby
> frogchorusfarm.com
> Snohomish, WA

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