permaculture

["Amy Little" <amylittle@hvc.rr.com>]

The Food Safety Modernization Act:  Comments Due this Monday Dec. 15
<http://sustainableagriculture.net/fsma/speak-out-today/> !

*    This is the first major overhaul of food safety laws in 76 years.

*    Farmers, food hubs, marketing and food system stakeholders, eaters: The
FDA needs to hear from us. 

*    To submit comments: easy instructions and tools can be found here
http://sustainableagriculture.net/fsma/speak-out-today/ 

*    Templates for Specific sectors:

.       Farmers, Food Hubs or other businesses - http://bit.ly/FSMAfarmer

.       Farmers Market Managers - farmersmarketcoalition:FSMA
MarketManagerCommentTemplate
<http://farmersmarketcoalition.org/wp-content/uploads/2014/11/2014_FSMA_FMC_
MarketManager_CommentTemplate_Final.docx> 

.       Consumers -  <http://bit.ly/FSMAconsumer> http://bit.ly/FSMAconsumer


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
<http://www.fda.gov/Food/GuidanceRegulation/FSMA/ucm379397.htmhttp:/>  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
<http://sustainableagriculture.net/fsma/overview-and-background/what-is-the-
produce-rule/> ), and Food safety measures for facilities that process food
for human consumption (Preventive Controls Rule
<http://sustainableagriculture.net/fsma/overview-and-background/what-is-the-
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 at this link http://sustainableagriculture.net/fsma/

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

Amy Little, NESAWG

Northeast Sustainable Agriculture Working Group

http://www.nesawg.org <http://www.nesawg.org/> 

845-255-0822 home office

845-853-3440 cell

amylittle@hvc.rr.com

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