{"id":54680,"date":"2021-02-09T16:34:42","date_gmt":"2021-02-09T21:34:42","guid":{"rendered":"https:\/\/sustainableagriculture.net\/?p=54680"},"modified":"2021-02-09T16:34:44","modified_gmt":"2021-02-09T21:34:44","slug":"fsma-its-back-and-farmer-comments-are-needed","status":"publish","type":"post","link":"https:\/\/sustainableagriculture.net\/blog\/fsma-its-back-and-farmer-comments-are-needed\/","title":{"rendered":"FSMA: It\u2019s Back! And Farmer Comments are Needed"},"content":{"rendered":"\n
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The photo is of a tomato harvest. USDA photo by Preston Keres.<\/figcaption><\/figure><\/div>\n\n\n\n

About six years ago<\/a>, the National Sustainable Agriculture Coalition (NSAC) kicked off a comment campaign around the Food Safety Modernization (FSMA) regulations that could negatively impact small farms, local food systems, and sustainable agriculture. Now, a new FSMA regulation is being proposed by the Food and Drug Administration (FDA), and FDA needs to hear organizations, food businesses, and farmers once again.<\/p>\n\n\n\n

Background<\/strong><\/h3>\n\n\n\n

FSMA included seven initial rules back in 2016<\/a>, most of which focuses on medium and large food businesses that process and distribute food nationally and internationally. FSMA\u2019s initial language limited the scope of FSMA on farms to the Produce Safety Rule<\/a>, unless the farm was conducting certain further processing that would require it to be regulated as a \u201cfacility<\/a>.\u201d<\/p>\n\n\n\n

Unfortunately, the new Proposed Rule on Requirements for Additional Traceability Records for Certain Foods<\/a> (\u201cTraceability Proposed Rule\u201d), encompasses farms, even though FSMA and Congress stated it was for facilities.<\/p>\n\n\n\n

The rule includes a number of additional recordkeeping requirements for farms, food businesses, grocery stores, processors, some cottage food operators, and anyone else who manufactures, processes, packs or holds products on the FDA\u2019s Food Traceability List<\/a> (FTL). These recordkeeping requirements might include required electronic spreadsheets, on farm GPS coordinates for where the food was grown and harvested, and the location, date & time that the food is harvested, cooled, packed, received, shipped, or used as an ingredient in another food.<\/p>\n\n\n\n

FDA is asking for comments<\/a> on this proposed rule, before it becomes final. The deadline for comments is Monday, February 22, 2021, at 11:59 pm Eastern Time.<\/strong><\/p>\n\n\n\n

For more information on the proposed rule and it\u2019s impact on farms, visit our posts: What the New FDA Rule Means for Farms Part 1<\/a> and Part 2<\/a>.<\/p>\n\n\n\n

FDA Needs to Hear from YOU about their Traceability Proposed Rule<\/strong><\/h3>\n\n\n\n

We need your help to ensure farms that are not facilities are removed from the rule, and that the rule ensures inexpensive and practical traceability for small food businesses. NSAC has developed a comment template<\/a> to help you craft a unique comment, specific to your farm or food business and its traceability system here<\/a>.<\/p>\n\n\n\n

Farms or businesses that might be exempt from the Traceability Rule should still comment. Even exempt farms might still be required to keep extensive records, because the proposed rule requires \u201cfirst receivers\u201d \u2013  businesses that receive food items first from the farm that grew, caught or harvested the food \u2013 to keep extensive records on where the food was grown and harvested. For example, a local food hub that is required to record the lot code, growing location, harvester, and farm contact information as a \u201cfirst receiver\u201d is likely to require the farm it purchases from to send along all of these records, since it is unlikely the food hub will be able to collect all of this information on their own. <\/p>\n\n\n\n

FDA only seriously considers unique comments, so please think through the questions on the template and the following questions as you write your comment:<\/p>\n\n\n\n