Page 83 - Fall2013

tee. The Senate will not accept a farm bill that WHAT you CAn do
omits the nutrition and assistance programs; Whatever happens with the Farm Bill, it is vital that your elected
even if this change somehow got through the officials know how you feel about your food! You can find out who repre-
Senate, the President has said he would veto the sents you by going to www.house.gov and www.senate.gov or by calling
bill the House passed. At the time this article the Capitol Switchboard at 202-224-3121. Ask to speak to the staffer who
goes to print, the House leadership had not even handles agricultural issues. Explain that you’re a constituent and that high-
appointed members for the conference commit- quality food is very important to you. Ask for their support for the Benishek
tee, although the Senate members were named Amendment in the Farm Bill (or a similar provision in another bill, if the
before Congress recessed in August. The Farm Farm Bill doesn’t pass). It is the responsibility of Congress to rein in the
Bill process is always full of twists and turns, FdA and prevent the damage that would be done by the proposed FSMA
but this year’s developments have been full of regulations.
surprises that make it impossible to predict what
may happen next.

Commenting on the FDA’s ProPoseD rules

Below are some talking points that you can use when submitting comments on the FDA’s proposed rules under FsmA.
it is important to personalize your comments, so be sure to include at least a couple of sentences about who you are
and why these issues are important to you. if you are a farmer or food producer, you will have the greatest impact by
pointing out the specific problems these rules will cause for your business and then sending a copy of your comments to
your u.s. representative and senators.

to submit comments on each rule, go to:
• On-Farm Produce Rule: www.regulations.gov/#!submitComment;D=FDA-2011-N-0921-0199
• Preventative Controls/HARPC Rule: www.regulations.gov/#!submitComment;D=FDA-2011-N-0920-0188

Tester-Hagan exemption (both rules):
1. The FDA should be held to specific, evidentiary standards before it can revoke a farmer’s or food facility’s Tester-
Hagan exemption.
2. A farm or facility that is exempt under the Tester-Hagan amendment should be given at least ninety days to submit
evidence and defend its exemption if FDA seeks to revoke it.
3. If the exemption is revoked, the farm or facility should have at least two years to come into compliance with the
FsmA rules. the FDA has other mechanisms it can use if there is an immediate threat of foodborne illness.

On-farm produce safety standards rule:
1. The FDA’s approach to traditional farming methods, such as diversified livestock-crop farms, the use of working
animals, and the use of biological soil amendments, is fundamentally flawed. the agency should not restrict these
sustainable methods of farming absent data showing an actual, verified increased rate of foodborne illness; the simple
fact that these methods include diverse microbiological communities is not a sound basis for restricting them.
2. The waiting period between applying manure and harvesting the crop should be no more than one hundred twenty
days, as has been the certified organic standard for almost two decades. similarly, there should be no waiting period
between applying compost and harvest. The excellent track record for safety on organic farms shows that this standard
is sufficient.
3. Compost teas should be treated the same as compost, whether or not there are additives such as molasses or kelp
meal included.
4. Water testing for irrigation and washing water should not be required more often than once a month, and farmers
should be able to test less frequently after establishing the safety of their water source through three consecutive
negative tests.

Preventative Controls and hArPC rule:
1. Low-risk activities conducted by a farm using its own products, such as making jams, grinding grains, or dehydrating
vegetables, should not be subject to these regulations.
2. Low-risk activities, when conducted off-farm or by multiple farms working together, should not be subject to the same
requirements as high-risk processing activities.
Wise Traditions FALL 2013 FALL 2013 Wise Traditions 81

123816_text.indd 81 9/20/13 1:00 AM