I am a field crew manager at a small organic-certified farm outside of Portland, Maine. I also teach a course on sustainable agriculture at a community college and I am an advocate for a more resilient food system. Whenever possible, I use scientific evidence to back my claims and make my case to my class and whoever else will listen. What concerns me most, after having attended a workshop on FSMA at a recent MOFGA conference, was how much the very knowledgeable farmer and advocate who led the workshop did not know about FSMA. To paraphrase, his assertion was that “if I say I don’t know how that’s going to work, then no one else does either.” I hope that FDA will apply more rigorous scientific and economic analysis of the practices called for and the implications of those practices. For instance:
-the myriad of marketing mechanisms currently in use on US farms far exceeds the number of mechanisms addressed in this legislation. The FDA should take steps to actively seek out the less common but completely legitimate markets and marketing mechanisms at play and see how these proposed rules will affect those farms and facilities.
-the testing of irrigation water, especially as it applies to surface water and even more specifically moving surface water, is not sensible or practical, and furthermore will be onerous to all farms, especially smaller operations.
-a 210-day waiting period on applying manure is ridiculous. Applying manure in September for an April planting is not only an ineffective application of manure because of nitrogen leaching and volatilization, but also increases eutrophication of waterways, which goes directly against the long-standing objectives of the NRCS and many of our conversation programs.
Furthermore, the workshop I intended helped elucidate for me what many of these exemptions mean, in that even if a farm or facility falls under these exemptions, they are still liable for these rules should a foodborne illness outbreak originate from said farm or facility. In other words, it’s not really an exemption but it fools small growers into thinking it is.
Please be considering all farm, facility and market types when creating a second proposed draft (and NOT a final interim rule…we would like another chance to look at what you come up with, please! Oh and we would also like to see and be able to comment on subsequent guidance), apply rigorous scientific and economic analysis to your proposed rules, see for yourself how ineffective certain of your rules will be in terms of guaranteeing food safety and also how incredibly difficult and expensive many of these standards will be to implement, and also consider grants and loans to make sure that farms and facilities can implement them while also staying in business.
Thank you for your time.
Cheers, Jeffrey Hake