MIFFS sends comments on FSMA
posted on December 18, 2013 1:59pm
On November 22, 2013, MIFFS submitted comments on Food Safety Modernization Act. Comments were regarding the proposed rule for Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption as well as the proposed rule for Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventive Controls for Human Food. As an organization representating beginning, small-scale, and historically marginalized farmers and ranchers, it is our hope that the implementation of these rules not impede the innovative economic development activities or ignore the investment of each farmer to find viable ways to feed their families and their regional communities.
MIFFS requested that FDA consider the following comments:
- Many of our farmers grow diversified crops in season extension hoophouses and on their farmland. FDA needs to retain an integrated approach to the standards for fruits and vegetables. We strongly recommend a collective crop approach versus separate required testing and regulations. Farms as a whole need to be regulated versus these individual crops. The farmers MIFFS serves have just begun to see real potential for economic viability in the food hub developments and regional food systems. Whole farm regulation keeps consumers safe and farmers able to continue building, season extension, sustainable operations.
- MIFFS wants FDA to ensure that the water testing while maintaining safe standards does not become a financial burden, including but not limited to an exemption from a rolling geometric mean.
- We believe FDA needs to include a fuller range of low-risk-value added processing activities in the final regulation, aligning with activities supported in each state (in Michigan many of our farmers are involved in salsa making, jam making, and pickling (to name a few of the highly sought after consumer product at local markets). These activities are historical and culturally important for the health and welfare of our marginalized communities.
- The smaller-scale farms that MIFFS works with depend on working collectively. They must support each other, particularly when it comes to attracting new buyers and getting their food to those consumers. FDA needs to clarify in the Preventive Controls Rule that CSA’s, Community Supported Agriculture, and other direct-to-consumer businesses such as cooperative sales at farmers markets and to restaurants, are not facilities subject to regulations for food facilities. This was part of the clear instructions from Congress.
- FDA should adopt at least the $1,000,000 threshold for very small businesses and make sure that that threshold is based on the value of regulated product, not on the value of all food. This would place the regulation on the largest amount of food products, and enable minority/small-scale producers to continue growing their businesses.
- Finally, MIFFS, its farmer constituents and their consumers are acutely aware of all our limited resources. MIFFS farmers are energized to implement soil conservation practices such as cover crops, responsible management of timber lots and wildlife surrounding farmland, and water conservation and erosion prevention techniques. FDA needs to incorporate stronger support for on-farm conservation that ties directly into food safety. No rule implementation should hinder conservation practices. Our limited resources must be protected and not diminished with overly ambitious actions.