December 8, 2014
Tell FDA to Consider the Bigger Picture With Food Safety
Small organic farmers need protection
Chemical hazards should be addressed
Last month FDA released proposed updates to rules under the Food Safety Modernization Act (FSMA). Although FDA adopted some recommendations addressing smaller scale and organic farm concerns made during the last public comment period for these rules, further action is needed by the Agency to reduce unnecessary burdens on local, organic farmers and further the ultimate goal of increasing the safety of the food we eat.
Tell FDA to protect small, organic farmers and take steps to avoid chemicals risks. Protecting organic farmers means protecting food safety because organic farmers are in the business of providing food produced with fewer risks and more care for the environment.
Despite a recent GAO report criticizing FDA for its lack of pesticide residue testing on food, the Agency continues to ignore one of the most serious threats to our food supply’s safety and did not address any of the concerns raised in Beyond Pesticides previous comments concerning the need to adopt better chemical safety standards for produce and processing.
Regarding chemical safety, FDA should:
- Revise the produce rule and preventative controls for human food rule;
- Include chemical hazards, pesticide residues, and biological impacts in its risk assessments;
- Acknowledge the full range of serious adverse health outcomes from chemical hazards that make their way into food;
- Incorporate procedures, processes, and practices that minimize contamination from chemical hazards; and
- Create explicit and defined practices to help retailers implement least-toxic alternatives.
Organic production methods and standards already provide a functional model. However, proposed revisions to the FSMA rules still place substantial burdens on small, organic farmers.
To protect local, organic farmers, FDA should:
- Decrease the costs to small farms and food processors by ensuring that environmental monitoring and testing are conducted in an efficient manner.
- Clarify that sale and distribution through a CSA, roadside stand, or farmers market is included in the definition of a “retail food establishment,” and not a “facility” that must be registered with FDA.
- Retain the threshold of at least $1,000,000 for a “very small business,” and apply sales to food regulated under the Preventative Controls Rule.
- Allow for farms with multiple landholdings to be treated as one farm, so as to not discriminate against cooperatives or food hubs.
- Incorporate stronger support for on-farm conservation practices by codifying in the preamble that farmers are encouraged to use sustainable conservation practices that enhance food safety.
Local organic farmers are good stewards of the environment and provide some of the only food sources free of the intense chemical hazards and adverse health effects associated with conventional agriculture. It is critical that FDA’s FSMA regulations encourage the food safety benefits for small organic farmers and reduce the burden on those who already make consumer health a priority.
To view FDA’s updated rules, view the federal register notice here.
For additional information, view Beyond Pesticides previous comments to FDA here.
This is a much longer message, so I am just posting the website and you can determine how much to read. But you can just sign the petition also.
Petition and Action Alert
Food Safety Modernization Act: New Draft Rules
Comments Due on December 15 to FDA