WVFFC response to FSMA developments

November 19, 2014   Tags:

Note: This article was originally published Oct 6 2014.

In November of 2013 the West Virginia Food & Farm Coalition weighed in on the impacts that the Food & Drug Administration’s proposed “Produce Rule” would have on West Virginia farms. The Produce Rule is part of the “Food Safety Modernization Act,’ or FSMA; a sweeping set of new regulations aimed at improving the safety of America’s food supply with regard to foodborne illness. Many of the requirements of the proposed rule would place a major burdens on Appalachian farms, particularly those practicing sustainable and organic techniques. In an effort to give farmers a voice, the Coalition submitted four pages of comments to FDA back in November asking them to revisit the requirements and make several changes. Last week the FDA announced that it did indeed make several changes to the proposed rules, including on many of the points we raised last year.

In our original comments to FDA, the Food & Farm Coalition asked FDA to issue a completely new set of rules that better takes into account the realities of small farm and sustainable agriculture (you can read the comments here). FDA did not re-open the entire Produce Rule, but instead made some changes to five different areas Rule related to water quality standards, use of manure and other amendments, wild animals on farms, how FDA determines who is covered, and their administrative procedure to withdraw an exemption. All five are areas that the Food & Farm Coalition asked FDA specifically to review (read an overview of our requests to FDA here).

FDA did not address the Food & Farm Coalition’s request to differentiate between foodborne illness originating on the farm and that originating at later food processing stages. The agency also did not address the need to protect the ability to have domesticated and work animals in the field.

The Food & Drug Administration is currently accepting comments to the supplemental rule only. The WV Food & Farm Coalition is in the process of reviewing the new rules to determine how they will impact small farms in West Virginia. We will be working with stakeholders and partner organizations, including the National Sustainable Agriculture Coalition, to assemble feedback and guidance for the FDA’s latest round of regulatory proposals. Watch this space for updates on how you can make your voice heard regarding the Supplementary Produce Rule.