New Jersey farmers are urged to send in comments by November 15th regarding the Proposed Produce Safety Rule and the Proposed Preventive Controls Rule. It is expected that about 20% of New Jersey farms will be expected to comply with the Produce Safety Rule. Several components of this rule have the potential to impact the financial stability of non-exempted farms and limit the growth of exempted farms.
At the Food Safety Modernization Act meeting held at the EcoComplex on Tuesday October 22nd growers expressed their concerns to FDA representatives. The most concerning portions of the rules are:
PRODUCE SAFETY RULE
Agricultural Water Testing Requirements – Subpart E
- Municipal water – You must have a copy of the municipal water testing certificate on hand
- Well water – At the beginning of the season and every three months during production
- Surface water (pond, stream, etc) – Every 7 days during production
- Surface water (well water pumped into a pond) – Once a month if there is no potential for contamination
Biological Soil Amendments of Animal Origin – Subpart F
- Raw manure applications – 9 month wait time from application to harvest of crop
- Purchased soil amendments – Must have a certificate of conformance from producer of product
- Compost – 0 – 45 day wait time from application to harvest of crop based on composting methods used
PREVENTIVE CONTROLS RULE
- When does a farm become a “facility”?
- How will farm income be calculated to determine compliance with this rule?
- How will the FDA define “holding” of product?
- What practices would qualify a honey producer to comply with this rule?
Growers Can Comment at the following website, or in writing to the address below.
Standards for Growing, Harvesting, Packing, and Holding of Produce for Human Consumption
Docket No. FDA-2011-N-0921
Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventive Controls for Human Food
Docket No. FDA-2011-N-0920
Division of Dockets Management (HFA-305)
Food and Drug Administration
5630 Fishers Lane, rm. 1061
Rockville, NMD 20852