Food Safety Modernization Act Rules

CISA has been closely following the implementation of the Food Safety Modernization Act, given the extent to which this Act will inevitably impact our local farms and food system.

Read on for information on how to impact the rules by submitting your comments to the FDA before the December 15th deadline!


The FDA’s draft rules for implementing the Act threaten to disproportionately impact our local farms. The FDA originally proposed the rules in January 2013 and then issued revised rules in September 2014 in response to extensive public comments from concerned citizens. The revised rules have addressed some, but by no means all, of our original concerns. These rules were created in response to food safety problems in the industrial food system, but the proposed regulations would have the unintended effect of increasing costs for small, diverse farms more than for large, industrial farms, threatening to put small farms out of business due to the high costs of compliance. All farms need to prioritize food safety practices, but the draft rules still do not fit the size or type of potential risks found on small farms.

Our advocacy efforts…

During the FDA’s first public comment period last year, CISA submitted detailed comments suggesting improvements to the rules, and hundreds of our members and stakeholders also commented on the rules. By the close of the public comment period, the FDA had received an unprecedented number of comments – over 25,000 – on the proposed rules! In response, the FDA made significant changes to the rules, but they did not go far enough. A second public comment period is now open on the revised rules. It is crucial that more comments be submitted in this final comment period to preserve these positive changes and address the significant remaining problems with the rules.

Please join us in submitting comments to the FDA by December 15, 2014!

Comment now!

Click here for information on how to comment on the rules.

For talking points, click here to read CISA’s detailed comments to the FDA on the revised rules. In addition, several local farm advocacy organizations have compiled excellent lists of talking points – see these links below to help guide your comments:

For more background…

Click here for the full comments CISA submitted to the FDA in November 2013, click here for CISA’s petition to the FDA last year with over 800 signatures and 200 individual comments, and click here to learn more about the rationale behind our suggested changes to the rules.