Learn About the Issues
This page is NOT updated to reflect current final rules. FDA released re-proposed sections of this rule on September 19, 2014. This text has been updated to reflect changes in the new version of the proposed rules, which were open for comment through December 15, 2014.
There are a number of issues in the proposed rules that are problematic for farmers and on-farm food processors. In addition, some issues affect both rules. We’ve explained the critical issues below. Get a short summary of the top 10 fixes and fails in the new FSMA rules on our blog.
Produce Rule Issues
- Definition of “Farm” and “Facility”: Do I Operate a Farm or a Facility?
- Manure and Compost
- Natural Resource Conservation Practices
- Domesticated and Wild Animals
- Agricultural Water
- Recordkeeping
- Exemptions and Modified Requirements
- Costs to Producers and Consumers
- Integrated Approach vs. Commodity-Specific Approach
- “All Food” vs. Covered Product
- Farm Registration
Preventive Controls Rule Issues
- Definition of “Farm” and “Facility”: Do I Operate a Farm or a Facility?
- Definition of a “Very Small Business”
- Food Safety Plan and Recordkeeping
- Modified Requirements for Qualified Facilities
- Costs to Producers, Facilities, and Consumers
- Facility Registration
- “All Food” vs. Covered Product
- Direct-to-Consumer Marketing Clarification
- Supplier Approval and Verification Program
- Environmental Monitoring and Product Testing