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Opinion: Grower Comments Underrepresented On Proposed Produce Food Safety Rules

Frank Giles By Frank Giles|October 11, 2013

Frank Giles

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Does a tree make a sound when it falls in the forest if there is nobody there to hear it? This question has been pondered by philosophers for many years. What’s more important, the noise or someone to perceive it?

You got me, but it does call to mind recent discussions on new produce food safety rules and the Food Safety Modernization Act (FSMA). There has been a lot of noise from the agriculture industry and federal regulators regarding the largest food safety overhaul in more than 70 years. Food safety stories posted on GrowingProduce.com have generated many comments from readers with varying points of view. We love it when you share your opinions, so keep them coming. Here’s a sample from one reader:

“Tree fruit should not be included in this FSMA mandate. The formulators of these food safety rules and regulations are trying to make one size fits all and that is not feasible for this crucial proposal. As written, this safety thing will put a lot of farmers out of business. Then the food consumed in the USA can all be imported from foreign countries that have little to no food safety regulations.”

Many of the comments reflect the sentiments above that these rules are too monolithic and could have detrimental effects, particularly on smaller growers. Regardless of your point of view, the rules are coming. In fact, new produce food safety rules already are posted online for comments by the FDA.

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This is where being heard comes in. The comment period is open until Nov. 15. Don’t miss the opportunity to make your voice heard on how these new regulations will impact your business — good or bad.

As of mid-September, about 1,064 comments had been made on the produce food safety rules. Of those, 1,030 were from consumers. One might expect more comments from consumers considering that growers now represent less than 2% of the population. But, that should be all the more reason to go online and comment. I recently attended a panel discussion that included representatives from FDA, and they were practically begging for comments from farmers on these proposed rules.

Don’t just assume that local or national specialty crop associations, which you may or may not be a member, will take care of commenting on the needs of growers. They are, but the associations and FDA are looking for “real-life” examples of how these rules will impact farming operations.

They want specifics about how water source rules might affect your irrigation practices or how fertilizer regulations might impact organic growers, etc. Be constructive and avoid hyperbole. If you assert these rules are going hurt your business, provide specific examples how they might.

The ability to comment on proposed federal regulations is your chance to be that noisy tree in the forest. By law, the FDA is required to hear it through the commenting period. It may or may not help change the regulations, but at least you’ve lent your voice to the rulemaking process.

To learn more about the rules or leave comments, visit Regulations.gov (FDA-2011-N-0921).

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Frank Giles is a former Editor of Florida Grower and Cotton Grower magazines, both Meister Media Worldwide publications. See all author stories here.

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Avatar for James Czarkowski James Czarkowski says:
October 16, 2013 at 8:18 am

I know the feeling. I now retired from nursing and in the context of medical businesses, the monies, and ways. Plus most people have no clue of where the food comes from. On the Net, living out of a can in the store, an illusion. I communicate with people in the Philippines and charities overseas, the real world of food supply, demand and production. Yes, food safety, by someone who grows it. Many times too busy or fear the time taxed in the political ways.

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Avatar for Matt Matt says:
October 17, 2013 at 12:05 pm

I think most growers don't comment as they feel their point of view will be ignored. It is how this administration works. They DON'T listen to those whom the regulations will affect. They rule by fiat, changing laws by executive action (not legal). If the federal regulators CARED about what growers thought, they would restrict the comments to growers only. When consumers force the regulations or regulators enact rules and processes that they know little or nothing about, then food production will shift to the largest producers who can absorb the costs and to foreign production where all of the rules don't apply. The FSMA will bankrupt most smaller growers. Anyone not NETTING more than $100,000 will be crushed by the new regulations. The modified rules as written apply to anyone selling more than 20K (Gross Sales), if I remember correctly. They estimated that complying with the rules will cost $1500. That is 7.5% of gross sales. How many produce farmers have more than 10-15% margin? Most have 5% or less. The new rules essentially take ALL of the profit. Why would anyone enter a business that is going to have ALL of the profit confiscated by the government under the guise of "Rules" and "Regulations". I don't think consumers realize nor care what happens to farmers. THEY would NEVER stand for a price increase in their product that is commensurate with cost of compliance. Consumers would naturally force retailers to buy more and more produce from foreign sources. It is hard now. I can offer pristine US Fancy Bell peppers to the local grocer at $20/case and they still buy pepper from Mexico, Holland, etc. and charge $2.99 or $3.99/lb. Institutions buy more local produce than retailers in most cases. If these new regulations go into force, then all of the extra paperwork will push most of the smaller producers, 100 acres and under, out of business. It is sort of like a thief asking you to comment on how he is going to rob you and how you would better like to be relieved of your cash. Most growers see it for what it is, communist style control of the food production system. Why do I say communist, because the FSMA is demanding that you must produce food the way the government tells you. REAL government sets guidelines and standards based on scientific standard (not which lobby group pays the most) and leaves it up to the grower/private industry to figure out a way to comply. This is all done with the understanding that the regulations are common sense and financially possibly. On a final note, what smaller grower has time to read hundreds of pages of PROPOSED laws and then try and figure out how that is going to affect his business? It is hard enough trying to get crops finished and sold to have to worry about fighting to keep his business open from government regulations.

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Avatar for tim miller tim miller says:
October 17, 2013 at 6:44 pm

I feel that most small scale growers are so concerned with potential USDA coming down on them to comply with stricter guidelines and force more small scale growers out of business for speaking up. It is big agriculture that will only win in these measures and they will continue to harm the safety of more citizens with unsanitary conditions at these mega farms. Especially concerning is the GMO and poultry industry.

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Avatar for anonymous anonymous says:
October 17, 2013 at 8:45 pm

I concur with Matt below. Three of the ten bulleted "demands" in the "Communist Manifesto" involve the state's meddling with agriculture. This is the obama administration's version of that meddling. In 2008 and 2012 the electorate sowed the storm and now it's reaping the whirlwind. These criminals in DC don't care what we have to say about anything; their sole purpose in life is imposing their will on us, through the mechanism of big government.

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