Sign-on to a joint organizational letter to the FDA requesting an extension of the FSMA comment period

Dear friends and allies,

As you may be aware, the FDA released its long awaited proposed rules on Food Safety Modernization Act on Jan. 4, 2013. Since then, organizations and individuals across the country have been scrambling to digest the massive rules and analyze the impact they may have on family farms and producers.

The sheer volume of proposed rules - and the coming spring planting - make it very difficult to have enough time to properly analyze the rules and provide substantive comments to the FDA before the May 16, 2013 deadline.

A few organizations that are particularly concerned about the impact of the rules on small-scale producers have drafted a letter to the FDA requesting a 120-day extension on the comment period. The full text of the letter is at the bottom of this page. We would like to submit this letter jointly with other concerned organizations.

An extension on the comment period will allow us all more time to ensure the new food safety rules do not undermine food safety by harming family farms and small-scale producers.

The deadline to sign on to the letter is Feb. 25, 2013. The letter is at the end of this page, as is a short form to add your organization's name. The letter will be submitted to the FDA soon after. For more information, contact Liz Moran with WORC (406-252-9672) or Judith McGeary with FARFA (254-697-2661).

For more information about the food safety rules, visit the FDA's Food Safety Modernization Act page at: http://www.fda.gov/food/foodsafety/fsma/default.htm.


Thank you,

Liz Moran
Western Organization of Resource Councils (WORC)
Billings, Montana
406-252-9672
lmoran@worc.org
www.worc.org

Judith McGeary
Executive Director
Farm and Ranch Freedom Alliance
www.farmandranchfreedom.org
Judith@FarmAndRanchFreedom.org
Office Phone: 254-697-2661


PRIVACY NOTE: Contact information provided on this page will only be used to list your organization as a signer on the letter to the FDA and to provide occasional updates on the FDA's proposed rules under FSMA. The list generated will not be shared or otherwise used by WORC, FARFA or any other organizations.

    Scroll down for the full text of the letter to the FDA.

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    The information provided will be used to list your organization as a signer on the letter to the FDA and to provide occassional updates on the FDA's proposed rules under FSMA. The list generated will not be shared or otherwise used by WORC, FARFA or any other organizations.

    Full text of Letter to the FDA requesting FSMA comment period extension:

    February ___ , 2013 Commissioner Margaret Hamburg Food and Drug Administration 10903 New Hampshire Avenue Silver Spring, MD 20993 Re: Comment period on FSMA proposed rules, Docket Nos. FDA–2011–N–0920 and 0921 Dear Commissioner Hamburg: The undersigned organizations urge you to extend the public comment period on the two major proposed rules under the Food Safety Modernization Act for an additional 120 days. Our organizations represent a wide range of constituencies, including organic farmers, conventional farmers, and consumers from across the country. While we recognize that the agency has provided more than the minimum comment period, the 120-day comment period in the proposed rule is still insufficient for several reasons: • The volume of material is overwhelming. The two proposals encompass over a thousand pages. There are hundreds of additional pages that must be reviewed to understand them, including both of the regulatory impact analyses and the draft qualitative risk assessment of activity/food combinations for activities conducted in a facility co-located on a farm. • The challenge of analyzing the rules stem from more than just volume of pages. The two rules have numerous points of intersection, and there are multiple outside references that need to be consulted to understand their probable application. • The spring months are busy for farmers as they prepare for and begin spring planting. Because of the widespread drought in 2012, many farmers are already stretched thin and must focus their efforts on their farm work. • Many of the affected farmers do not have internet access. According to the 2007 Census of Agriculture, more than 40 percent of farms do not have internet access. In addition, several undersigned organizations have Amish and Mennonite members, who can only be contacted by mail or through print publications. In turn, comments from these farmers and ranchers will need to be conveyed to the FDA by US mail. This dynamic demands more time for dialogue among a large percentage of the affected constituency. • Substantively, we have identified numerous areas that will require extensive discussion among our constituencies to understand the full impacts. For example, the restrictions on the use of biological soil amendment of animal origin have very different potential impacts in the northeast, where vegetable-based amendments are more easily accessed, than in western states, where manure-based composts and amendments are commonly used. The length and complexity of the proposed rules is multiplied by the wide divergences in the ecosystems and types of operations affected. The undersigned organizations represent a wide diversity of constituencies, and we need more time to talk with our members before submitting comments. It is critical that the agency extend the comment period and that it do so as soon as possible. Our organizations face difficult decisions in spreading the word to our members, including the use of resources to send first class mail or bulk (less expensive but slower) to reach those without internet access. Waiting until the last minute to announce the extension would impose unnecessary burdens on nonprofits who are doing a service for both the public and the government by notifying people of the proposed rule and the opportunity to comment. For these reasons, we urge you to immediately announce an extension of the public comment period until September 13, 2013, providing a 120-day extension for public comment. We thank you for your consideration. Sincerely, [Organizations listed] For more information, please contact Judith McGeary, Farm and Ranch Freedom Alliance, 512-484-8821, or Sara Kendall, Western Organization of Resource Councils, 202-547-7040. Cc: Secretary Kathleen Sebelius

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