Federal Food Safety Background

 
In December 2010, Congress passed a food safety bill that significantly expanded FDA’s authority, including mandatory recall and inspections. But the bill does not ensure that FDA will use its new authority responsibly, nor does it address the revolving door between the agency and industry, epitomized by Michael Taylor’s current position as FDA’s food czar following his work for Monsanto. Most importantly, the Act does not address the underlying causes of most foodborne illness, namely the industrialized agriculture production and processing systems. These fundamental flaws mean that the bill will most likely do very little to actually improve food safety.

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The Safety of Farmers’ Markets

Bad Science Behind the Recent Attack

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On January 17, Professor Bellemare, an economist at the University of Minnesota, published an opinion piece in the NY Times claiming that his research showed a correlation between the number of farmers’ markets and the number of food-borne illnesses in a state.

 

Even taking Bellemare’s claim at face value, it simply doesn’t mean a lot. Correlation does not mean causation. There are numerous examples of meaningless correlations, such as a graph that was developed showing that the rise in autism correlates with the rise in consumption of organic foods – although no one would contend that there’s a logical connection between those two trends.

 

Moreover, the way Bellemare found this supposed correlation was deeply flawed. The only data used were the number of farmers’ markets in each state and the number of foodborne outbreaks and illnesses in each state.…

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FDA’s Final Produce Rule Imposes Undue Burdens on Farmers

Download the pdf version of this press release here

AUSTIN, Texas – November 17, 2015 – The Food and Drug Administration’s (FDA) final rule for farms that raise produce for human consumption, “is going to be very damaging for the growing local food movement, and the millions of American consumers who want more access, not less, to healthy local foods,” stated Judith McGeary, founder and Executive Director of the Farm and Ranch Freedom Alliance, and a farmer herself.

The final rule comes after two rounds of proposed rulemaking, an unusual procedure taken by FDA in response to the outcry caused by the initial proposed rule. The final rule retains many of the positive changes that had been made in the second proposed rulemaking, but FDA made only a few additional changes.

“On the positive side, the final rule retains the changes relating to the use of compost and manure, as well as adding some clarification on grazing and the frequency required for water testing,” stated Ms.…

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FDA issues first major rule under Food Safety Modernization Act

On September 17, FDA formally published the first major final rule under the Food Safety Modernization Act (FSMA) in the Federal Register.

This final rule addresses the standards for “facilities” that sell food for human consumption. The rule has staggered deadlines for compliance, so that large businesses will have to come into compliance in November 2016, while small businesses will have an additional one to two years depending on their size.

(The Produce Safety Rule, the other major rule under FSMA, is supposed to be finalized by late October of this year.)

This first published final rule implements FSMA’s requirement that businesses that manufacture, process, pack, hold or store food implement “hazard analysis and risk-based preventive controls” (HARPC), including a written food safety plan that identifies the possible problems that could affect the safety of their products and outlines steps the facility would take to prevent or significantly minimize the likelihood of those problems occurring.…

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Tell Congress to support local meat production

We have an exciting opportunity to expand access to locally produced meat for consumers around the country! U.S. Representatives Thomas Massie (R-KY) and Chellie Pingree (D-ME) have introduced legislation to make it easier for small farms and ranches to sell locally raised and processed meat to consumers.

H.R. 3187, the Processing Revival and Intrastate Meat Exemption (PRIME) Act, would give individual states the freedom to permit intra-state distribution of custom-slaughtered meat to individual consumers and to restaurants, hotels, and grocery stores that directly serve consumers. Custom-processed beef, pork, lamb, and goat are covered under the bill.vaca-y-vino-meat

Under current federal law, farmers often have to haul their animals several hours away to reach a slaughterhouse that has an inspector on-site, even if they’re selling the meat directly to consumers at a local farmers market or similar venue. This increases expenses for the farmer, raises prices for consumers, creates stress on the animals, and undermines the concept of local food.…

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Comments needed on FDA’s proposed registration requirements

 

The FDA is proposing a new regulation that amends the current requirements for any business that holds, stores, manufactures, or processes food (termed “food facility”) to register each location with the FDA.

The Tester-Hagan amendment to the federal Food Safety Modernization Act sought to reduce the sfarmers-market-jarscope of this pre-existing requirement by exempting any food business that sells the majority of its food directly to consumers at locations such as roadside stands and farmers markets. The amendment directed FDA to develop a list of other direct-to-consumer venues that would be considered, and the agency has developed a rather comprehensive list.  But the FDA’s proposed rule only exempts farms selling at such direct-to-consumer locations  — leaving many small artisan food producers subject to unnecessary regulation.

In addition, for those businesses that must register, the proposed rule requires electronic registration and a contact email address.  The proposed rule also requires that every food business also register with Dun & Bradstreet’s system to get a universal number, which is then also filed with the FDA. …

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FARFA Comments on HARPC Rule 2014

CLICK HERE for a downloadable PDF version of this document.

Division of Dockets Management (HFA-305)
Food and Drug Administration
5630 Fishers Lane, Room 1061
Rockville, MD 20852

December 15, 2014

Re: Preventive Controls Rule: FDA-2011-N-0920

Dear FDA:

The undersigned organizations represent farmers, food businesses, and consumers across the United States. We jointly submit these comments on the proposed rule for Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventive Controls for Human Food (hereinafter, proposed HARPC Rule).

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FARFA Comments on Produce Rule 2014

CLICK HERE for a downloadable PDF version of this document.

Division of Dockets Management (HFA-305)
Food and Drug Administration
5630 Fishers Lane, Room 1061
Rockville, MD 20852

December 15, 2014

Re: Produce Standards Rule: FDA-2011-N-0921, and RIN 0910-AG35

Dear FDA:

The undersigned organizations represent farmers, food businesses, and consumers across the United States. We jointly submit these comments on the re-proposed rule for Standards for Growing, Harvesting, Packing, and Holding of Produce for Human Consumption (hereinafter, proposed Produce Rule).

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Tester-Hagan Sign On Letter 2014

[CLICK HERE TO DOWNLOAD PDF VERSION OF THIS LETTER]

Division of Dockets Management (HFA-305)
Food and Drug Administration
5630 Fishers Lane, Room 1061
Rockville, MD 20852
December 15, 2014

Re: Preventive Controls Rule: FDA-2011-N-0920
Produce Standards Rule: FDA-2011-N-0921

Dear FDA:

The undersigned organizations, farms, food businesses, and concerned individuals jointly submit these comments on the Tester-Hagan provisions, also referred to as the qualified exemptions, in the proposed rules under the Food Safety Modernization Act (FSMA).

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Action Alert: Keep Small Farmers and Food Producers in Business

farm-closed-crop

Take Action on FDA’s 2014 Proposed Food Safety Regulations!

The FDA’s re-proposed Food Safety Modernization Act (FSMA) rules will have a disastrous impact on small, sustainable farms and food businesses if they are approved as written. Many producers will have to raise prices, or could be driven out of business, reducing consumer access to local, healthy foods.

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Action Alert: Protect Small Farmers and Food Producers from FSMA Regulations

small family farm

Updated November 5, 2014.

We fought hard for the Tester-Hagan amendment to exempt small-scale, direct-marketing farms and artisan food producers from the most burdensome aspects of the Food Safety Modernization Act (FSMA). This exemption is essential to the continued vitality of the local foods movement.

Now the FDA is proposing rules that would make it very easy for the agency to force even small-scale farmers to comply with the onerous FSMA regulations, and all but impossible for these vulnerable farmers to protect themselves.

Consequences of the Proposed Rules

Under the proposed rules, if the FDA decides to revoke the Tester-Hagan exemption and force a small-scale, direct-marketing farmer or artisan food producer to comply with the new federal requirements:

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