Lee J. Stivers - Comment

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As an Extension Educator working with vegetable and fruit producers in Pennsylvania, I have concerns about how the implementation of FSMA will affect our large number of smaller scale, highly diversified producers. Specifically:
High cost of implementation, documentation and repeated testing (e.g. water, compost) threaten the viability of a farming system that is largely sustainable in our state.
Interpretation of some of our more complicated direct marketing channels (produce auctions, cooperatives, CSAs)
Small family farmers with diversified operations may unexpectedly fall into the “over $500,000” total food sales category even if their fresh produce sales are $25,000 or less.
Strict limits and long time intervals on the use of animal manures may have a negative impact on otherwise sustainable farming practices, such as crop rotations, nutrient management, integrated production systems.
How can we reasonably include draft animals? Many of our producers are members of Plain Communities (Amish, Mennonite) and this segment of produce producers is growing in Pennsylvania.
Members of Plain Communities cannot use information technologies that would make recordkeeping and documentation efficient.



Lee J Stivers Comment

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Authors: CFSAN

Comment Period Closed
Sep 16 2013, at 11:59 PM ET
ID: FDA-2011-N-0921-0153
Tracking Number: 1jx-85n5-2pgx

Document Information

Date Posted: Jun 3, 2013
RIN: 0910-AG35
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Submitter Information

Category: Academia - E0007