Comments on: FSMA: It’s Back! And Farmer Comments are Needed

By: Sarah Hackney

Sarah Hackney — Mon, 22 Feb 2021 20:13:51 +0000

Thank you for your comment, Barbara! Please submit your comment to the Federal Register here too: https://www.regulations.gov/commenton/FDA-2014-N-0053-0184

By: Sarah Hackney

Sarah Hackney — Mon, 22 Feb 2021 20:13:40 +0000

In reply to Jane Abbott-Rider.

Thank you for your comment, Barbara! Please submit your comment to the Federal Register here too: https://www.regulations.gov/commenton/FDA-2014-N-0053-0184

By: Sarah Hackney

Sarah Hackney — Mon, 22 Feb 2021 20:13:31 +0000

In reply to Carl Glanzman.

Thank you for your comment, Barbara! Please submit your comment to the Federal Register here too: https://www.regulations.gov/commenton/FDA-2014-N-0053-0184

By: Sarah Hackney

Sarah Hackney — Mon, 22 Feb 2021 20:13:21 +0000

In reply to jane.

Thank you for your comment, Barbara! Please submit your comment to the Federal Register here too: https://www.regulations.gov/commenton/FDA-2014-N-0053-0184

By: Sarah Hackney

Sarah Hackney — Mon, 22 Feb 2021 20:13:14 +0000

In reply to Barbara Rosholdt.

Thank you for your comment, Barbara! Please submit your comment to the Federal Register here too: https://www.regulations.gov/commenton/FDA-2014-N-0053-0184

By: Barbara Rosholdt

Barbara Rosholdt — Sat, 20 Feb 2021 21:02:34 +0000

I oppose this rule!
Small farm businesses (such as mine) are not facilities that should be required to report the “traceability” of the food produced on site. With a small operation there is no need to prove where the food came from (usually just feet away). We are not capable of providing the necessary information due to the constraints of running a tight operation that pays attention to the health of the product, the soil, and the customers who eat the produce. This rule would make small farming nearly impossible. With so many challenges already at play, we should not be required to provide this technological information (which will not benefit the farmer in any way). Please consider small farms and their product exempt from this rule, as scale matters!
The rule should not apply to farms that are not facilities. The proposed rule is not consistent with FSMA’s language that instructed FDA to write a rule “for facilities that manufacture, process, pack, or hold foods that the Secretary designates” as high-risk foods. Applying the rule to farms that are not facilities is not consistent with the law, unduly burdensome for farms, especially local, sustainable farms, and is costly for small farms with thin margins.

By: jane

jane — Thu, 18 Feb 2021 15:56:28 +0000

By: Dianne Hungo

Dianne Hungo — Thu, 18 Feb 2021 15:45:17 +0000

As a buyer from small independent farmers I know the struggle these folks have between the weather and rules and regulations. The weather can’t be controlled but the rules can be. These new regulations should not apply to small farms, those that are not facilities or big farming operations. Consider the population that prefers supporting the common man.

By: Carl Glanzman

Carl Glanzman — Thu, 18 Feb 2021 13:41:32 +0000

Small local food providing farms should be exempt from onerous record keeping requirements. We supply just 3 small restaurants with salad greens triple washed, broken up and bagged in 1 pound bags, ready to serve.
Each delivery specifies weight and items in those bags on the delivery invoice. The items that may be in the salad mix are clearly displayed on the invoice. We pring duplicate invoices and save 1 copy for our files.
An episode where our process might result in a claim of illness or lack of cleanliness can be traced to 4 or 5 bags (usual daily order at the largest of our small client restaurants) at that establishment.
We see no need for further documentation that is no t required by virtue of the current law, as we do not store such produce on our farm.

By: Jane Abbott-Rider

Jane Abbott-Rider — Mon, 15 Feb 2021 11:02:41 +0000

Dear FDA,
I oppose the proposed rule on traceability. Many small farms like ours do not have the man poswer to make spread sheets all their required records let alone within 24 hours. I am the farmer, secretary and farm hand. I can not hire extra folks…especially at the proposed minimum wages of this administration! We will NOT be able to provide clean, organically managed food which is important to the environment. You can not have it both ways!

I am also a prescribing healthcare provider. I used to teach microbiology. This is an absurd traceability rule from a health perspective. An exemption of 10 employees or less needs to be written into the language. Our clients can already trace their food to our farm without a spread sheet!

The rule should not apply to farms that are not facilities. The proposed rule is not consistent with FSMA’s language that instructed FDA to write a rule “for facilities that manufacture, process, pack, or hold foods that the Secretary designates” as high-risk foods. Applying the rule to farms that are not facilities is not consistent with the law, unduly burdensome for farms, especially local, sustainable farms, and is costly for small farms with thin margins.