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COMMENT: NSAC Responds to the FDA’s Proposed Rule Regarding the Agricultural Water Provisions of the Food Safety Modernization Act

December 2, 2021


Contact: Laura Zaks

National Sustainable Agriculture Coalition


Tel. 347.563.6408

COMMENT: NSAC Responds to the FDA’s Proposed Rule Regarding the Agricultural Water Provisions of the Food Safety Modernization Act

Washington, DC, December 2, 2021 – The National Sustainable Agriculture Coalition (NSAC) issued the following comment, attributable to Eric Deeble, NSAC Policy Director, in response to the US Food and Drug Administration (FDA)’s proposed rule published today that would revise the Food Safety Modernization Act (FSMA) Produce Safety Rule to change certain pre-harvest agricultural water requirements for covered produce other than sprouts:

“For over a decade, NSAC has been working to ensure that important food safety guidelines for farmers are sufficiently simple, flexible, and centered on risk. We are closely reviewing FDA’s newly released proposed Agricultural Water Standard rules now. It is our hope that the proposed agricultural water assessment approach will allow farms to individually assess their risks and tailor mitigation methods to each farm. Upon initial review, we appreciate the agency’s move away from the previous rule, which was too focused on a set number of tests and a testing regimen that would have resulted in significant and disproportionate costs to small, diversified farm operations. 

At its core, this rule continues to place the burden of assessment and mitigation of hazards solely on fruit and vegetable farmers. Problems with agricultural water quality need to be addressed at a societal and systemic level, instead of expecting farm by farm enforcement to correct a problem that originates upstream. The Coalition also remains concerned about the rule’s encouragement of chemically treated water and the potential environmental impact of this element of the rule.

We urge FDA to continue to listen to the diverse range of farmers affected by this rule and collaborate closely with their colleagues at USDA to ensure that all producers are aware of this comment opportunity. 

We look forward to further reviewing this rule and gathering feedback from our members on the impact it will have on sustainable, diversified farm operations.” 


About the National Sustainable Agriculture Coalition (NSAC)

The National Sustainable Agriculture Coalition is a grassroots alliance that advocates for federal policy reform supporting the long-term social, economic, and environmental sustainability of agriculture, natural resources, and rural communities. Learn more and get involved at: https://sustainableagriculture.net

Categories: Food Safety, Press Releases

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