NSAC Submits Comments to FDA on Co-Management
October 7, 2011
The Food Safety and Modernization Act (FSMA) was enacted into law at the beginning of this year, and the rulemaking process for the legislation is currently underway, with the proposed rule expected to be submitted for public comment near the start of next year.
The FSMA includes several provisions that are related to wildlife and the environment. NSAC’s Food Saftey Taskforce submitted a memo to the FDA on October 5 that provides suggestions on how to best address these provisions in regards to the potential conflicts between conservation concerns and the produce safety rule. The produce safety rule is one of several rules that will implement congressional directives in the FSMA.
The memo addresses the definition of “co-management,” provides an assessment of three FSMA mandates, and provides possible language and concepts that should be reflected in the Produce Rule.
Some of the key points made in the memo include:
- Resolving any conflict of interest between the Produce Rule and farming practices that were installed pursuant to conservation programs or environmental regulations.
- Farmers should not have to bear the burden of reconciling agency differences, and should be provided with financial assistance through federal conservation programs if they need to comply to new regulations.
- Non-crop vegetation decreases pathogen risk and should not be removed.
- The Produce Rule should promote planting of hedgerows and grass water strips, cover cropping, and composting to decrease pathogen transmission.
- Control of livestock can be more effective as a pathogen control method and should take priority over control of wildlife on farming operations.
- Integrated crop and livestock systems are important to environmental quality and pathogen control.
- New food safety rules must allow farmers to continue conservation efforts, such as proper composting, that are in accordance with National Organic Program standards.
Conservation, Energy & Environment, Food Safety, Organic