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Food Safety on the Agenda

Posted by Michele Spencer at Jan 11, 2013 05:56 AM |
Dear PASA Members & Friends,

The first few days of 2013 brought some extraordinary events that will likely affect the sustainable agriculture movement for many years to come.

First there was the debacle on New Year's Day when we woke up to find that the so-called "fiscal cliff" deal in Congress, hammered out in the middle of the night, also included a 9-month Farm Bill extension with some curious features. While retaining the subsidy programs for commodity crops, essentially all of the more-or-less sustainable provisions of the bill were missing in the extension. This is an unprecedented event - as just about everything happening in Washington DC is these days - and the situation will remain this way unless and until a new 5-year Farm Bill (or additional extension) can be passed with some of these provisions that sustainable ag advocates had fought many years to establish are restored. Let's just say, we're not holding our breath, but will let you know what's happening as the situation unfolds.
But another huge event that happened, just a week ago today, was the long-awaited release of new food safety regulations by the FDA, representing almost 2,000 pages of material that must be absorbed, understood and responded to by public comment within 120 days. These regulations are coming two years after the new Food Safety Modernization Act was passed and signed into law, and a year later than required by the law itself - the long delay was almost certainly a result of the recent presidential election. There are in fact still some parts of the new regulations to be released presumably later in 2013.

The two main pieces of regulation are titled respectively as the Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption, which is rather self-explanatory, and the Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventive Controls for Human Food, which is more easily understood as the rules for food processing facilities. The full text of each is available on the PASA website at the link provided. Before anyone gets frustrated by the length of these documents, please be aware that the bulk of each is in the form of a preamble, and the actual proposed rules are relatively short by comparison.

PASA has been involved in this process since the very beginning - in the spring of 2009 - and we're not about to back out of it. However, now that the "rubber is hitting the road" so to speak, we're going to need the help of many of you out there to do our jobs thoroughly and most effectively. Namely, we need some of you who will be directly affected by these rules to read them and give us some feedback in the shorter term, and as the comment period comes to a close in the springtime, we'll need many others of you to join us in writing relevant comments for submission to FDA.

I am already in touch with sustainable and organic farming leaders across the country to begin an organized analysis of the rules, and many of us will be gathering next week to plan in greater depth. As a result, I expect to know much more about how this will all play out by the time our conference rolls around in early February, and we are currently planning to add a special session on Saturday at the conference to present what is known by then, and to take your questions and comments about both the rules and the process for responding. So please, if you're on the fence about coming to the conference, this will be a great reason to come, in order that we can collect your impressions and thoughts about what must be addressed in person, and you can hear what your fellow PASA members have to say as well. Registration details are available here.

One of the most critical discussions that must be initiated is regarding the "exemptions" (in quotes because no one is really exempted from providing safe food by the new law) that PASA helped to get into the law for operations selling food within 275 miles and grossing less than $500K, i.e. the so-called Tester-Hagan amendment. There are certain circumstances under which such exemptions can be revoked, and we plan to look very closely at those provisions in particular.

This is one of those times, as with issues like milk labeling in the past, when the entire PASA family must act as a team in order to look out for the common good. This does not mean that we will all agree on what the new rules should say, or even that there should be new rules at all. Indeed, we are most effective when we respond in a way that reflects the diversity that is our community. We look forward to working with you toward that end, and ask you to stay tuned for additional information in the coming weeks. In the meantime, please feel free to contact me directly if you have immediate questions or suggestions.

Thanks all, and see you at the conference!

Brian

Brian Snyder, Executive Director
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