Farmer Co-ops Submit Comments on Food Safety Proposals


Washington, D.C. (December 16, 2014)—The National Council of Farmer Cooperatives (NCFC) on Monday submitted comments to the U.S. Food & Drug Administration (FDA) on four supplemental notices for comments that are part of the implementation of the Food Safety Modernization Act (FSMA).

“As the FDA continues the implementation of FSMA, NCFC will continue to advocate for policy based on sound science, that is risk based and commodity specific,” the organization said in its comments. “NCFC applauds FDA’s revised effort to implement FSMA [and] commends FDA for recognizing that significant changes were needed and allowing the public the opportunity to provide input on FDA’s new thinking.”

The four rules open for comment were the:

(1) Foreign Supplier Verification Programs for Importers of Food for Humans and Animals (FSVP rule);

(2) Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventive Controls for Human Food (Human Food Preventive Controls rule);

(3) Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption (Produce Safety rule) and

(4) Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventive Controls for Food for Animals (Animal Food Preventive Controls rule).

NCFC urged changes related to the use of sales cut offs in several definitions within the FSVP rule and the Human Food Preventive Controls rule; in particular it was noted that the proposed language within the rules be tweaked to take into account that many co-op members record proceeds from delivery of product as patronage returns rather than sales.

Other suggested changes were the inclusion of producer-owned packing and sorting facilities under the definition of “farm” in the rules and urging the use of science-based criteria in the rules.

“NCFC and the farmer co-op community remain committed to working with the FDA to ensure the safety of the food that millions of Americans feed their families every day,” said Chuck Conner, president & CEO of NCFC. “We believe that we have identified areas where the four proposed rules could be changed to better achieve the food safety goals outlined in FSMA and we look forward to seeing the FDA’s final versions of the rules.”

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