Food Safety

NSAC and our members work with farmers and farm and food enterprises of many shapes and sizes that are committed to providing the safest food possible in a manner that is economically viable, environmentally sound, and equitably accessed. We see food safety in the context of many other risks to our shared food systems, such as the long term loss of topsoil, species diversity, natural resources, consumer choice, and opportunities for farms and rural communities; the concentration of wealth, power, and ownership in the hands of fewer and fewer food system players; and the measurable but unpredictable impacts of the industrial model as applied to agriculture, among many others. Sustainable food systems seek to counter these trends by increasing opportunity and transparency in the food system and reconnecting consumers with farmers. And at the center of reconnecting consumers with the food they eat are questions about food safety.

NSAC is currently focused on ensuring that federal food safety rules and requirements are developed and implemented in a way that ensures the ongoing viability of sustainable and organic agriculture and promote the continued growth and development of local and regional food systems. This work involves participating in the development and implementation of the Food Safety Modernization Acts rules, inspection protocols, and guidance documents; monitoring any new rule making actions related to these rules; working to ensure robust and appropriately tailored food safety training is available and accessible for small and mid-sized farms and small-scale food businesses; and supporting programs that provide farmers with the tools they need demonstrate compliance with good agricultural practices and meet market requirements.

For the latest news on food safety, visit our blog!

Learn More About NSAC’s work on food safety!

• FDA and FSMA: Working to ensure the implementation of the federal food safety rules supports and does not undermine sustainable food and farm systems.
• Training: Providing the tools and resources farmers and food entrepreneurs need to prepare for and adapt to new food safety requirements.
• Good Agricultural Practices (GAPs): Helping produce farmers, packers, and distributors meet the food safety certification requirements of buyers.

FDA and FSMA
Due to a rise in major outbreaks of foodborne illnesses and increasing bioterrorism concerns after 9/11, both Congress and the Obama Administration proposed new food safety measures in 2009 that expanded food safety regulations to the farm level. Previously, food safety regulatory oversight was focused mainly on the processing, food handling, and manufacturing sectors – areas shown to be of highest risk for foodborne pathogen contamination.

In 2009 and 2010, Congress debated a number of food safety proposals that directly and indirectly affected farms and on-farm processing. These proposals extended regulatory authorities to farms and made some on-farm safety standards mandatory. Given the potential impacts of these new food safety proposals on sustainable food production, NSAC created a task force and engaged in the legislative debate.

NSAC’s priority was to make sure that the new food safety measures worked for sustainable and organic farmers, and for consumers who wanted access to fresh, local food. Due to NSAC’s leadership and the actions of thousands of farmers and concerned consumers, the new food safety law that Congress passed and that President Obama signed – the Food Safety Modernization Act (FSMA) – included the following critical provisions:

• Scale-appropriate regulations: Rejecting a “one-size-fits-all” approach, FSMA includes options for small, mid-sized, and direct-market agricultural operations to comply with equivalent state regulations or modified, scale-appropriate federal regulation.
• Conservation practices: Recognizing that conservation practices have a number of public benefits, FSMA indicates that new regulations should not undermine beneficial on-farm conservation and wildlife practices.
• Organic production: Acknowledging that organic production and food safety go hand-in-hand, FSMA specifies that new regulations must complement – not contradict – strict regulations for certified organic production.
• Value-added processing: Supporting the development of new low-risk processing businesses, FSMA minimizes extra regulations for low-risk processing that is part of value-added production.
• Paperwork reduction: Recognizing the burden on smaller operations, FSMA streamlines and reduces unnecessary paperwork for farmers and small processors, and prohibits expensive testing and audit requirements.
• Farm identity-preserved: Accepting that identity-preserved marketing has built-in traceability attributes, FSMA allows farm identity-preserved marketing as an option in place of government trace-back controls.
• Training: Supporting the importance of training and capacity building, FSMA authorizes a new competitive grants program to train farmers and processors on food safety.

The Food and Drug Administration (FDA) is in the process of implementing FSMA and has finalized two rules in particular that will have significant impacts for sustainable farmers, on-farm food processors, and consumers who care about where their food comes from. NSAC engaged significantly in the rulemaking process to ensure that the protections for sustainable agriculture and local food systems were reflected in the final rules.

Together with our members and allies, we led a national effort that resulted in tens of thousands of comments on the proposed rules from farmers, food businesses, consumers, and the organizations that represent them. These comments led FDA to reconsider several of the most contentious aspects of the 2013 proposed rules and propose revised standards for public comment in 2014. These proposed rules — one of which sets new standards for produce farms, and another which adds new requirements to food facilities, including on-farm value-added processing — were both finalized in the fall of 2015, but there’s still work to do!  NSAC will continue working to ensure that the rules are implemented in a manner that is reflective of congressional intent to support both food safety and sustainable food and farm systems.

Recent NSAC Actions on FSMA

• FSMA Diagrama de flujo Español (July 2018)
• Revised “Am I Affected” Flowchart to reflect final rules (July 2018)
• Briefing on Need for Farm Bill Food Safety Investments (Feb 2018)
• Comments to FDA’s “Questions and Answers Regarding Food Facility Registration” Draft Guidance (Oct 2016)
• Issued FSMA Training Resources for Farmers (Oct 2016)
• Published Two FSMA Special Reports (Aug 2016)
• Comments to FDA’s Biological Soil Amendments of Animal Origin Risk Assessment Docket (July 2016)

Historical NSAC Actions on FSMA

• Produce Safety Rule Draft Guidance Comment Template (April 2019)
• Comprehensive analyses of both Preventive Controls Rule (Sept 2015) and Produce Rule (Nov 2015)
• Submitted comments on FDA’s proposed clarification of the “retail food establishment” exemption (June 2015)
• Submitted comments on FDA’s implementation docket (May 2015)
• Stakeholder panelist at FDA FSMA Implementation Public Meeting (April 2015)
• Submitted comments on Produce Rule Draft Environmental Impact Statement (March 2015)
• Led a national campaign to educate farmers, food businesses, and consumers on the potential impacts of the proposed FSMA rules (Jan-Nov 2013), which resulted in tens of thousands of comments to the dockets and a significant rewrite to portions of the proposed rules and another opportunity for public comment (Sep-Dec 2014), which resulted in thousands more comments to FDA and significant changes to the final rules.

Resources and Analysis

• Carolina Farm Stewardship Association Interactive Guide to Food Safety Modernization Act for Local Food Businesses and Farms
• Carolina Farm Stewardship Association Interactive FSMA Produce Rule Flowchart 
• Community Alliance with Family Farmers Food Safety Plan Templates 
• Future Harvest CASA Food Safety Toolkit (Mar 2020)
• Young Farmers’ Food Safety Resource Library
• Young Farmers’ A Small Farmer’s Practical Guide to Food Safety (Jan 2020)
• Young Farmers’ Food Safety Case Studies
• Food Facility Registration Q&A Adds Clarity to Food Safety Requirements (Sept 2018)
• The Challenge of Assessing Food Safety Compliance Costs (June 2017)
• Smaller Farms Likely to Face Higher Food Safety Compliance Costs (Aug 2018)
• Update: Food Safety Modernization Act Exemptions (Apr 2018)
• “Enforcement Discretion” Policy to Enhance Flexibility While FDA Fixes Food Safety Rules (Jan 2018)
• FSMA Training Frequently Asked Questions (Oct 2016)
• Clear and Consistent Food Safety Standards Could Benefit People and the Environment
• Understanding FDA’s FSMA Rule for Produce Farms, NSAC Special Report (Aug 2016)
• Understanding FDA’s FSMA Rule for Food Facilities, NSAC Special Report (Aug 2016)
• FDA Extends Compliance Deadlines for New Food Safety Rules
• Wild Farm Alliance Co-Management Handbook for Farmers  (Jan 2016)
• Food Safety Training Resources
• Food Safety Outreach Program

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Training
Training farmers in food safety practices is a critical piece of ensuring a safe food supply. And when Congress passed the Food Safety Modernization Act (FSMA) in 2010, it recognized the importance of training as a part of a prevention-oriented food safety system focused. Accordingly, FSMA authorized a competitive grants program to be administered by USDA’s National Institute for Food and Agriculture to fund farmer and food processor training efforts.

This program is intended to target small and mid-sized farms, beginning and socially disadvantaged farmers, and small-scale food processors and merchant wholesalers – the entities identified as most vulnerable to the impacts of new food safety requirements. It is also intended to take an integrated approach to food safety training, and be workable for a diversity of production practices including, in particular, sustainable and organic agriculture, and the co-management of conservation and food safety practices.

FDA and USDA have worked together to award several grants under this program to establish a system of national and regional centers that will coordinate food safety training, outreach, education, extension, and technical assistance nationwide. NSAC is working to ensure that this program fulfills the intent of Congress and directs the majority of available funds to community-based nonprofit organizations working directly with farmers and small food businesses to allow them to provide appropriately-tailored tools and resources that farms and food enterprises need to come into compliance with new food safety rules.

For more information on food safety training grants, visit our Grassroots Guide!

Recent Actions on Food Safety Training

• NSAC’s FY 2017 appropriations priorities include $10 million for food safety training
• Food Safety Outreach Program awards $4.7 million to on-the-ground farmer training projects in FY2016
• NSAC wins 100% increase in FY2016 appropriations bill for food safety training
• FDA and USDA announce National and Regional FSMA Training Center award recipients
• NSAC’s submitted recommendations to USDA and FDA to inform the launch of the food safety training program in April 2014 and January 2015. NSAC has continued to submit recommendations to the USDA about the Food Safety Outreach Program each fiscal year.

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GAPs
To provide a standard food safety audit system for producers, packers, and distributors, USDA and various inspection and standardization agencies developed the Good Agricultural Practices (GAP) and Good Handling Practices (GHP) Audit Verification Program. The GAP and GHP program is a voluntary, user-fee funded independent audit program offered to the produce industry to verify that fresh fruits and vegetables are produced, packed, handled, and stored according to food safety practices that minimize the risks of microbial food safety hazards. The audits are based on recommendations from the U.S. Food and Drug Administration (FDA) and open up new markets for producers, packers, and distributors seeking to sell to schools, grocers, wholesalers, and others that require food safety certification. NSAC member organizations work with USDA to provide GAPs training to produce farmers in their states and regions.

USDA and FDA are currently working on aligning the USDA GAPs program with the new FSMA requirements, so that GAP certification can provide farmers with the confidence that they are also in compliance with FSMA. As the go-to certification program for many small and mid-sized produce farmers, NSAC is working to ensure that the USDA GAPs program, including the new GroupGAP certification option, remains a relevant and viable option for family farmers.

Action on GAPs

• Carolina Farm Stewardship Association’s Farmer’s Handbook to USDA Harmonized GAP Standard (2018)
• GroupGAP Becomes Available Nationwide (April 2016)

For more information about the USDA GAP/GHP program, visit our Grassroots Guide!

Visit NSAC’s FSMA Action Center for historical information on the food safety rules.

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