FSMA Listening Session with VAAFM and NEASDA

Food safety regulations will affect farmers and food processors throughout the country, and NOFA Vermont has been one of many voices calling for these regulations to be amended to be appropriate for organic and small-scale farms. We hope that concerned farmers, processors, and consumers will continue to make their voices heard, as well. This announcement comes from the Vermont Agency of Agriculture. The Vermont Agency of Agriculture, Food, and Markets (VAAFM), in conjunction with the Northeast Association of State Departments of Agriculture (NEASDA), will host an open Listening Session on November 17^th, 2014, to offer farmers and food processors an opportunity to provide comment on new supplemental rules proposed by the federal Food Safety Modernization Act (FSMA). Attendees will have an opportunity to pose questions to and seek clarification from a panel of subject matter experts from the Food and Drug Administration (FDA) that will be present at the meeting. The listening session will take place from 9:00am – 1:00pm in the Chase Center located at the Vermont Law School in South Royalton, VT. While oriented towards regional farmers and food processors specifically, this listening session is open to all interested parties from across the northeast. FSMA, the most sweeping reform of our nation’s food safety laws in more than 70 years, was signed into law by President Obama on January 4, 2011. FSMA aims to ensure the safety of the U.S. food supply by shifting the focus from responding to contamination to preventing it. On September 29^th, 2014, the FDA released proposed supplemental rules to four of the seven existing rules, largely the result of an unprecedented level of comments and valuable input received from farmers and others directly affected by these regulations.

The November 17^th, 2014, the Vermont-NEASDA hosted listening session will focus on the following three supplemental rules:

1. The Standards for the Growing, Harvesting, Packing, and Holding of Produce rule proposes enforceable safety standards for the production and harvesting of produce on farms. Changes include:

• More flexible criteria for determining the safety of agricultural water for certain uses and a tiered approach to water testing.
• A commitment to conduct extensive research on the safe use of raw manure in growing areas and complete a risk assessment. Pending those actions, FDA is deferring its decision on an appropriate time interval between the application of raw manure, the harvesting of a crop, and removing the nine-month interval originally proposed.
• The FDA proposes eliminating the 45-day minimum application interval for composted manure that meets proposed microbial standards and application requirements.

2.  The Current Good Manufacturing Practices and Hazard Analysis and Risk-Based Preventive Controls for Human Food rule would require makers of food to be sold in the United States, whether produced at a foreign- or domestic-based facility, to develop a formal plan for preventing food products from causing food borne illness. 3.  Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventive Controls for Food for Animals would require facilities producing animal food (pet food, animal feed, and raw materials) to have written plans that identify hazards and specify steps to prevent those hazards. Changes include:

• Requirements that human and animal food facilities, when appropriate, test products and the food facility’s environment, as well as implement certain supplier controls.

A full copy of the proposed supplemental rules is available for viewing through the following links:

• Proposed Supplemental Rule for Produce - http://www.fda.gov/Food/GuidanceRegulation/FSMA/ucm334114.htm
• Proposed Supplemental Rule for Current Good Manufacturing Practices - http://www.fda.gov/Food/GuidanceRegulation/FSMA/ucm334115.htm
• Proposed Supplemental Rule for Preventive Controls for Animal Food - http://www.fda.gov/Food/GuidanceRegulation/FSMA/ucm366510.htm

All growers, manufacturers, and anyone interested in fresh produce safety and manufacturing of human and animal food are encouraged to comment on the supplemental proposed rules. The comment period will remain open for 75 days until December 15^th, 2014. There are two ways to officially submit comments to FDA:

1. Comment electronically at:
   1. Produce: https://www.federalregister.gov/articles/2014/09/29/2014-22447/standards-for-the-growing-harvesting-packing-and-holding-of-produce-for-human-consumption
   2. Human Food: https://www.federalregister.gov/articles/2014/09/29/2014-22446/current-good-manufacturing-practice-and-hazard-analysis-and-risk-based-preventive-controls-for-human
   3. Animal Feed: https://www.federalregister.gov/articles/2014/09/29/2014-22445/current-good-manufacturing-practice-and-hazard-analysis-and-risk-based-preventive-controls-for-food
2. Written comments may be faxed to the FDA at 301-827-6870 or you may mail them to:

Division of Dockets Management (HFA-305)

Food and Drug Administration

5630 Fishers Lane, Room 1061

Rockville, MD 20852

For more information about FSMA, visit http://www.fda.gov/Food/GuidanceRegulation/FSMA/ Or contact: Abbey Willard – [email protected] or 802-272-2885 Shelley Mehlenbacher – [email protected] or 802-828-2421