April 22, 2016
The National Sustainable Agriculture Coalition (NSAC) and our members are surveying produce farmers to better understand how they use and apply untreated or raw manure on their farms.
Between now and June 3, 2016, we are collecting anonymous information to develop comments for the Food and Drug Administration (FDA) to aid in their development of a risk assessment model. This model will be used to pursue an appropriate standard for the application of raw manure as part of the Produce Safety Rule.
The fact that FDA is even asking for this type of input is a reflection of the huge victory that NSAC and the sustainable agriculture community achieved during the Food Safety Modernization Act (FSMA) proposed Produce Safety Rule comment period. As followers of this issue may recall, FDA had proposed rules that would have severely restricted the ways in which farmers use manure – particularly regarding the length of time between the last application of raw or untreated manure to a field and when a produce crop is harvested from that field.
Comments from NSAC and its members demonstrated to FDA that their proposed approach (a nine month waiting period) did not adequately account for regional variations in climate and growing seasons, nor the diversity of production practices that farmers use across the country. As a result, FDA agreed to revisit risk assessment of raw or untreated manure application procedures. This request for information by FDA is the first step in that process.
FDA has committed to doing a full risk assessment that will look at pathogen survival while considering different agricultural and ecological conditions (e.g., soil types, application methods, geographic locations, climatic factors) and considering different time intervals between when manure is applied and the crop harvested. The risk assessment will eventually inform FDA’s next proposed standard setting a required minimum time interval for raw or untreated manure application.
To make sure this risk assessment and the final standard fully account for the diversity of ways in which farmers use biological soil amendments, particularly raw or untreated animal manure, NSAC is seeking information from produce farmers via this survey.
Click here to take the survey!
About the Survey
This survey is primarily intended for farmers who apply untreated or raw manure or other biological soil amendments of animal origin to fields where produce is grown. Examples of manure that might be used include: cattle manure, poultry litter, swine slurry, and horse manure, or products such as compost or compost tea using such products.
The survey is not intended for farmers who do not grow produce, do not use manure or manure-based compost at all, or who use only purchased manure that is labeled or marketed as treated or composted.
The survey is divided into five sections that collect information on farm profiles, soil characteristics, crop production practices, manure application habits, and pathogen testing. Farmers with multiple produce farms are requested to respond in the context of just one particular farm where untreated manure amendments are commonly used. The survey also includes several open-ended questions to allow farmers to provide their own comments. The survey should take no longer than 25 minutes, and all survey responses will be anonymous. No identifying information will be shared with FDA.
We’re asking produce farmers to complete this survey by June 3, 2016 so that we can begin aggregating responses and integrating them into the comments we will provide to FDA by the extended comment period deadline of July 5, 2016.
We recognize this is a busy time of the year for farmers, and appreciate any time that can be spared to respond. Farmer input at this stage is incredibly valuable and will help ensure that FDA’s new food safety standards work for sustainable agriculture.
Please feel free to share this survey with farmers in your networks.
You can learn more about FDA’s Risk Assessment process here.