Support Fresh, Safe Local Food in the Food Safety Bill
The undersigned organizations represent consumers, small farmers and ranchers, and local food
producers who have serious concerns over the pending food safety legislation,
S.510, the Food Safety Modernization Act.
We urge you to support amendments so as to improve food safety without unnecessarily
burdening and handicapping small-scale, local food producers.
All of the well-publicized incidents of contamination in recent years – whether in
spinach, peppers, or peanuts – occurred in industrialized food supply chains
that span national and even international boundaries. The food safety problems in this system can
and should be addressed without harming the local food systems that provide an
alternative for consumers.
The growing trend toward healthy, fresh, locally sourced vegetables, fruit, dairy,
and value-added products improves
food safety by providing the opportunity for consumers to know their farmers
and processors, to choose products on the basis of that relationship, and to
readily trace any problems should they occur.
Farmers and processors who sell directly to consumers and end users have a
direct relationship with their customers that ensures quality, safety,
transparency and accountability. In
addition, small-scale food producers are already regulated by local and state
authorities, and the potential risk their products pose is inherently limited
by their size. For these farmers and
processors, new federal requirements are unnecessary and would simply harm both
the food producers and their consumers.
Although the Committee-passed bill includes some provisions for flexibility for small and
diversified producers, S. 510 still would establish new hazardous analysis and risk-based
preventive controls for all facilities and authorize FDA to dictate growing and
harvesting practices for produce. These requirements will impose significant
expenses and burdens on individuals and small businesses.
Hazard Analysis and Risk-Based Preventive Controls
We therefore urge you to support Senator Tester’s
amendment to exempt small, local processing facilities from the bill’s
hazard analysis and risk-based preventive controls requirements and
1) With respect to the hazard analysis and risk-based preventive controls, add the following new section to Section 103:
(l) EXEMPTION FOR CERTAIN FACILITIES – This section shall not apply to a facility for a year if the average annual adjusted gross income
of such facility for the previous three-year
period was less than $500,000.
2) With respect to traceability, add the following new section to Section 204:
(f) EXEMPTION FOR CERTAIN FACILITIES – The traceback and recordkeeping requirements under this section shall not apply to a facility for
a year if the adjusted gross income of such facility for the previous year was
less than $500,000.
FDA Produce Standards
We also request that you consider an amendment to exempt direct-marketing farms from the FDA
produce standards. With respect to the produce standards, add the following new
section to Section 105:
(g) EXEMPTION FOR DIRECT MARKET FARMS – This
section shall not apply to farms whose annual value of sales of food products
directly to consumers, hotels, restaurants, or institutions exceeds the annual
value of sales of food products to all other buyers.
Food safety is a priority for us all. We share the
concerns that have led to this bill and appreciate Congress’s commitment to
addressing these problems. Thank you for
your consideration, and for your support of a safer, more sustainable food
system and consumer access to healthy, local foods.
Dakota Rural Action
Dakota Resource Council
Farm and Ranch Freedom Alliance
Idaho Rural Council
Northern Plains Resource Council
Oregon Rural Action
Organic Consumers Association
Powder River Basin Resource Council
Western Colorado Congress
Western Organization of Resource Councils
SmallHolders Alliance of Massachusetts ""