US: NSAC comments to FDA on proposed food safety regulations

The National Sustainable Agriculture Coalition (NSAC) has submitted comprehensive comments to the Food and Drug Administration’s (FDA) proposed regulations for produce safety and for preventive controls for facilities that manufacture human food. NSAC also submitted comments on the environmental impact scoping process that is part of the produce safety regulations. The proposed rules are in response to the Food Safety Modernization Act (FSMA) of 2010.

“NSAC’s comments on the proposed regulations reflect the concerns of sustainable and organic farmers and food businesses that are pioneering farming practices and food supply chains to increase consumer access to healthy food, sustain the environment, and create new economic opportunities,” said Ariane Lotti, NSAC’s Assistant Policy Director. “NSAC’s recommendations are aimed at improving the regulations so that they advance food safety goals while simultaneously supporting sustainable agriculture and food systems.”

As proposed, the regulations will severely restrict the use of sustainable farming practices, inhibit diversification and innovation in farming and short supply chains, and fail to provide workable, affordable options for family farmers.

“The proposed regulations fail to meet the requirements that Congress set forth in FSMA for a flexible approach that reflects different risks at different scales and supply chains,” said Lotti. “Given the size and scope of serious problems in the proposed regulations and the lasting impacts they will have on the farm sector, NSAC joins the National Association of State Departments of Agriculture and the United Fresh Produce Association in urging FDA to issue a set of second proposed rules so the public can meaningfully comment on what we hope will be a major overhaul of their initial drafts.”

Throughout the comment period, FDA conducted listening sessions and farm tours to receive feedback and learn about how farmers and food businesses would be impacted by the proposals.

“NSAC is grateful for the agency’s outreach during the comment period, and looks forward to continuing to work with FDA to craft flexible, science-based regulations that support agricultural diversity and a healthier food system,” said Lotti. “Supporting thriving local and regional food systems and ensuring a safe food supply are complementary, not competing, goals.”

NSAC’s comments are the result of eleven months of analysis and discussion by NSAC’s Food System Integrity Committee, the NSAC committee charged with working on the Food Safety Modernization Act (FSMA). To develop the recommendations, the committee liaised weekly by phone and twice in person during the public comment period.

NSAC’s complete comments on the proposed Produce Rule, the Preventive Controls Rule, and the environmental impact scoping notice are available at

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