With respect to the requirements on manure and compost, the proposed application intervals (9 months and 45 days, respectively) will conflict with and restrict organic operations' ability to rotate crops as part of a preventative pest and disease control and to comply with the established NOP regulations at 7 CFR 205.205 (Crop rotation practice standard).
National Organic Coalition (NOC) and Organic Trade Association (OTA) have provided summaries, talking points, and templates for submitting comments. See below.
The National Organic Coalition (NOC) provided the following:
The FDA is taking comments from the public until Friday, November 15.
It is crucial that everyone is involved in crafting these rules. The National Sustainable Agriculture Coalition (NSAC) has created helpful documents (all available on their website) regarding background information, details about the rules, and an easy way to make your voice heard in this process. All comments are due Friday, November 15.
The Food Safety Modernization Act (FSMA) is the first major overhaul of our nation's food safety practices since 1938. It represents large and dramatic changes to our food system - for farmers, processors and consumers. You may be directly affected by these proposed rules.
Specifically, the FSMA rules would require significant controls on Manure, Compost, Compost Tea, and Water (irrigation and wash water and testing), including potential changes in organic standards regarding the use of compost. The requirements are complex and numerous - see NSAC's full analysis HERE -, but requirements include:
- A 45-day interval if the amendment has been applied in a manner that minimizes the potential for contact with covered produce during or after application, and if the amendment has undergone a scientifically valid controlled composting process that satisfies the microbial standard forSalmonella and fecal coliforms
COMPOST TEA: FDA considers agricultural tea to be untreated if it contains an agricultural tea additive.
FDA is proposing to require a nine-month interval between application and harvest if the soil amendment is untreated and there is chance that the amendment will come into contact with covered produce after application.
The National Sustainable Agriculture Coalition has developed comment templates for farmers, processors, and consumers in word documents that can be edited and added to, and include step-by-step instructions to assist in filing the comments online. See easy links to these steps, below.
- Background information and rules overview
- Learn more about the critical rules
- I'm a farmer. I'm a processor. How am I affected by these new rules?
- Get involved and take action
Get informed and determine how you may be affected by the rules - some farmers and processors may be eligible for exemptions or modified requirements, but even if so, the rules could still impact you!
Customize the comments for yourself! There are guiding questions here to help you tell your story effectively to FDA.
- Submit your comment in TWO places - to the Produce Rule and to the Preventive Controls Rule. This is important because these issues affect both rules.
- Take a stand publicly and sign the NSAC FSMA petition! Then help spread the word!
The Organic Trade Association (OTA)'s FSMA links:
View the Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption Proposed Rule. Also referred to as the “Produce Safety Rule.”
View OTA’s Summary of the Produce Safety Rule
View OTA’s Summary of Who Would be Covered by the Rule
View OTA's Talking Points on the Produce Safety Rule
View OTA's Talking Points on the requirements for compost and manure
View OTA's Presentation on draft comments on the Produce Safety Rule
The National Sustainable Agriculture Coalition (NSAC)'s FSMA information page: <http://sustainableagriculture.net/fsma/>