This bill will kill small farms, and wreck our food supply

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 traceability requirements.

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.

For more information, contact Sara Kendall at 202-547-7040 or sara@worc.org, or Judith McGeary at 512-243-9404 or Judith@FarmaAndRanchFreedom.org.

Sincerely,

Amend-S510-April-15

QA-Tester-Amendment-April-15