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.
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).