The FDA accepted comments on the Supplemental Rules for the Food Safety Modernization Act until December 15, 2014.
The website will only give you a short period of time to write your comments, so we suggest writing your comments in a word document and then cutting and pasting it into the Federal Register.
The National Sustainable Agriculture Coalition has excellent summaries of all of the issues and templates for making comments here.
Ginger Nickerson's comments to the Federal Register on the Supplemental Produce Rules are here.
Vern Grubinger has summarized some of the most significant issues here.
Produce Safety Coordinator Ginger Nickerson has put together this Summary of FSMA Supplemental Revisions for Produce Rule, summarizing some of the most significant changes, what they mean for Vermont growers, and highlighting issues on which the FDA is especially interested in receiving comments.
The changes include:
Produce Safety: More flexible criteria for determining the safety of agricultural water for certain uses and a tiered approach to water testing.
Produce Safety: 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 and the harvesting of a crop and removing the nine-month interval originally proposed. FDA also proposes eliminating the 45-day minimum application interval for composted manure that meets proposed microbial standards and application requirements.
Preventive Controls for Human and Animal Foods: Requirements that human and animal food facilities, when appropriate, test products and the food facility's environment, as well as implement certain supplier controls.
The FDA will accept comments on the revised provisions for 75 days after publication in the Federal Register, while continuing to review comments already received on the original proposed rules. No additional comments will be accepted on the original proposals. FDA will consider both sets of comments - on the original proposed rules and on the revisions - before issuing final rules in 2015.
These were developed during the public comment period that closed in late 2013 and early 2014, but have information on the projected impact of the proposed legislation that may be valuable as you attempt to assess what it could mean for your operation.