You've been hearing about this from us for almost 10 months now, but the time is now to take action and comment on the proposed food safety (FSMA) rules by the Nov. 15 deadline. Keep in mind it is not likely another chance to affect these regulations this deeply will come around in our lifetimes — it is indeed critical that you express yourself now!
A very strong coalition of sustainable and organic farming leaders, working through the National Sustainable Agriculture Coalition (NSAC), has been poring through the thousands of pages provided by FDA to understand what's going on, and while no one fully understands, our team as a whole has the most thorough knowledge of the proposed rules and implications that I've seen out there anywhere.
The most significant issues needing attention have been boiled down for you — particularly the farmers — so that you can choose among them for comment, or maybe work down the list and do them in several pieces over the remaining time. You can file comments as often as you wish (by Nov. 15), but keep in mind that issues of relevance to both the Produce and Preventive Controls rules (as with exemptions) must be filed in both places to be considered separately.
For your convenience, NSAC has also developed templates for both farmers and consumers to follow, at least to get you started. These, and several other helpful documents, are available on our website. There is also a petition to sign, sponsored jointly by NSAC and Farm Aid — we suggest that everyone do that first, and then proceed to the issues page and templates to make more meaningful comments. It is particularly important that farmers weigh in as thoroughly as you are able, since yours are the voices and stories that will carry the most weight.
In addition to all of the above resources, I also want to draw your attention back to the Write to Farm blog I started earlier this year to address food safety and other issues. There are several posts there of relevance, including the most recent entitled FDA's Culture of Fear Threatens Food Safety. Please consider discussing this issue of institutional culture as part of your comment introduction or summary, as it's probably the most important matter not otherwise covered in the actual written rules. Other particularly helpful posts would be the following:
I can't emphasize enough the importance of not only taking action yourselves, but also getting this email, the information on the PASA and NSAC websites, the Write to Farm blog, the comment templates, and at very least the petition, in front of your neighbors, friends, colleagues, customers and other potentially interested parties, while there's still time to make a difference. If you use Facebook or Twitter, we suggest using the hash tag #fixFSMA as well.
We need a flood of concern at FDA headquarters to make this point, that when it comes to food safety, local and sustainable food systems are part of the solution, not the problem!