Today marks the end of a major step in the implementation of the Food Safety Modernization Act (FSMA): the public comment period for the Food and Drug Administration’s (FDA) proposed food safety rules — for produce safety (Produce Rule) and for facilities that manufacture food for human consumption (Preventive Controls Rule) — closes today.
Since the release of the proposed regulations at the beginning of January, NSAC’s Food System Integrity Committee has been meeting weekly by phone and twice in person to analyze, discuss, and prepare recommendations on the regulations based on feedback from sustainable and organic farmers and food businesses through the country. Last week, NSAC submitted comprehensive comments to FDA on its proposed Produce Rule and Preventive Controls Rule, as well as on the environmental impact scoping process accompanying the Produce Rule:
- NSAC Produce Rule Comments (PDF)
- NSAC Preventive Controls Rule Comments (PDF)
- NSAC EIS Scoping Notice Comments (PDF)
Throughout the comment period, NSAC led a coordinated effort to provide resources through our FSMA Action Center to farmers, concerned consumers, and organizations interested in understanding and commenting on the proposed regulations. NSAC member organizations conducted farmer listening sessions, organized comment writing parties, and found creative ways to engage farmers and consumers in a complex set of regulations through social media, videos, informational materials, and countless hours of in-person outreach.
We extend a big thank you to all the farmers, food business, and concerned consumers who commented on the proposed regulations, and to NSAC member and partner organizations that submitted comments. The comments are critical to helping FDA understand the complexity and diversity of farming and food systems, as well as the potential impacts and unintended consequences of the proposed rules. The comments are also extremely important for fixing the rules so that the regulations simultaneously support food safety goals and thriving sustainable food and farming systems.
Now that the comment period is closing, FDA will be reviewing the comments and working to revise the regulations. NSAC, along with other agricultural organizations, is calling on FDA to release a second proposed rule for public comment before finalizing the regulations, given the significant problems in the proposed rules and given the lasting impact they will have. There are also a number of comment periods on other proposed rules that are still open for public comment, including regulations for animal food and imported food.
If you haven’t yet submitted your comments, there is still time (until 11:59 EST tonight!). For information about the rules and instructions on how to comment, visit our FSMA Action Center.
NSAC’s press release on our FSMA comments is available here.
For the long term health and safety of the soil where food begins, respect must be given to the evolutionary co-dependence of plants and animals and this is hampered by these rules. The rules need to be re-thought. Diversified farms provide more food security which in the long run means food safety.