Petition Against the Food Safety Modernization Act!

We share a deep commitment to supporting the small and diversified family farms of Western Massachusetts, and to the continued growth of our local food system.  Local agriculture is strong in the Pioneer Valley region – with over 150 farm stands, forty farmers’ markets, and countless restaurants and grocery stores offering local food.   We are lucky to have such a thriving local food system, and access to farm-fresh food is something we deeply value as a community.

We ask that you make changes to the proposed rules under the Food Safety Modernization Act to ensure that they do not put our local family farms out of business, and that they do not reverse decades of progress toward building a thriving, sustainable local food system.  Healthy local food systems are key to food safety and food security.

In particular, we request that the FDA make the following changes to the rules:

1. Remove requirements that discourage sustainable farming practices, including those allowed and encouraged under federal conservation programs and organic standards.  Specifically, the rules must not inhibit farmers from producing compost and using manure to enrich fields; they must not encourage farmers to remove wildlife from their fields; and they must not require widespread use of chemical treatments for water.
2. Provide low-cost alternatives that are appropriate for small farms.  The high costs that the proposed rules would impose on small farms are untenable, and local farms lack the resources to establish alternatives to these one-size-fits-all rules, even when the rules permit this.
3. Strengthen and expand the exemptions for small farms based on the lower risk they pose to consumers.  Specifically, family farms with sales of less than $1 million (most of whom take home only a tiny fraction of that) should qualify as “very small businesses,” and sales should be determined based on only the part of the operation that is covered under these rules
4. Protect the exempt status of small farms by clearly outlining a fair procedure that the FDA must follow to remove a farm’s exemption based on scientifically measurable risks, as well as a fair procedure for reinstating the exemption.

Thank you for your consideration.

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