NASDA Submits Comments On Two Food Safety Rules

The National Association of State Departments of Agriculture (NASDA) recently submitted comments on the Food and Drug Administration’s (FDA) proposed Produce Safety Rule (FDA-2011-N-0921) and the Preventive Controls for Human Food (FDA-2011-N-0920). Both rules are part of a package of proposed rules created under the Food Safety Modernization Act (FSMA). These comments are part of a nearly yearlong effort by NASDA’s FSMA Technical Working Group.

“Since FDA’s release of these rules earlier this year, we have been working diligently to review these important rules and draft meaningful comments for FDA’s consideration” said Katy Coba, Oregon Director of Agriculture and Chair of NASDA’s Food Regulation and Nutrition Committee.  “The Produce Safety and Preventive Controls for Human Food Rules will affect farmers, large and small, in every state.  The current drafts are very complex.  We hope to help make the rules more understandable for farmers and consumers alike. It is imperative we get this right for the future of agriculture.”

NASDA is currently examining three additional rules: Foreign Supplier Verification Programs (FSVP), Preventive Controls for Animal Food, and Accreditation of Third-Party Auditors. Currently, the deadline for comments on the FSVP and Third-Party Auditors Rules is January 27, 2014. Comments on the Preventive Controls for Animal Food Rule are due on February 26, 2014. To date, over 13,000 comments have been submitted on the initial draft of the Produce Safety Rule and nearly 6,000 on the Preventive Controls for Human Food Rule.

Two additional rules, Transportation and Intentional Contamination, are also expected to be released. NASDA will submit comments on all of the rules and encourages all sectors of the agriculture community to submit comments to the FDA as well.

NASDA President and Vermont Secretary of Agriculture Chuck Ross has recently hosted webinars and listening sessions to bring awareness to FDA’s proposed rules and their implications to agriculture in his home state of Vermont.

“State departments of agriculture are strong advocates for food safety and understand the farmers, ranchers, and food processors that feed our nation,” said Ross. “Preventive food safety regulation of the produce industry has not been a part of the FDA’s responsibility in the past, and it is critical to get these rules right. We feel strongly that a second draft should be published for public input before the rules are finalized.”

In anticipation of the major learning curve that will be needed for farmers to understand and comply with these new rules, the North Carolina Department of Agriculture & Consumer Services tested a pilot training program this summer. Steve Troxler, North Carolina Commissioner of Agriculture and Past President of NASDA, recognizes the education and technical assistance that will be needed to help producers understand potential problems.

“We recognize the monumental task that we all face, helping fruit and vegetable producers understand the new rules,” said Troxler. “We brought farmers in for training, helped them develop voluntary food safety plans, and offered voluntary farm visits. We can make a huge difference in compliance if we help farmers to understand best practices. The U.S. has the safest food safety system and it is the primary responsibility for everyone in our food supply chain to achieve that.”

NASDA is a nonpartisan, nonprofit association which represents the elected and appointed commissioners, secretaries, and directors of the departments of agriculture in all fifty states and four U.S. territories. To learn more about NASDA, please visit www.nasda.org.

Source: National Association of State Departments of Agriculture (NASDA)