Elizabeth Graser-Lindsey - Comment

This is a Comment on the Food and Drug Administration (FDA) Proposed Rule: Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption; Extension of Comment Periods

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Since my family operates a small farm and my daughter is in the process of beginning a larger farm in Oregon, we are aware of the problems created if the Food Safety Modernization Act does not consider how it might negatively impact small farms without positively affecting food safety.

We are able to operate in a clean and reliable manner because we are able to give attention to detail. Our friend told us about on her small farm where my daughter interned that her milk pus counts were far below typical numbers. We consume our own products and we want safe, healthy food.

HOWEVER, we need to achieve quality food without bearing expenses that would put us out of business as we scarcely can make a living already with food prices being so low for the producer.

Both Rules. The cost of compliance needs to be kept to a minimum and FDA needs to provide free training to very small producers.

Produce Rule.

E coli is not an appropriate measure of water borne illness as it has various strains and other organisms such as Salmonella are not necessarily associated with it. Weekly water tests are too expensive for the smaller operations and unnecessary.

Manure applications should not be treated like other soil amendments nor should rules interfere with conservation practices.

Manure and compost applications do not need to be separated from harvest time by more than the National Organic Program requires.
Comment Period Closed
Nov 15 2013, at 11:59 PM ET
ID: FDA-2011-N-0921-0247
Tracking Number: 1jx-8819-vvsk

Document Information

Date Posted: Oct 25, 2013
RIN: 0910-AG35
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Submitter Information

Category: Food Industry - C0027