Natural Resource Concerns. In 2007 there were a number of food borne illness attributed to fresh...
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The Food Safety Modernization Act Natural Resource Concerns
Natural Resource Concerns. In 2007 there were a number of food borne illness attributed to fresh produce People became sick Business’s lost market share
In 2007 there were a number of food borne illness attributed to
fresh produce People became sick Businesss lost market share
Lawyers became rich
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Stakeholders and policy makers came together
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Produce Safety Standards - Published Jan. 16, 2013 Preventive
Controls for Human Food - Published Jan. 16, 2013 Foreign Supplier
Verification Program Preventive Controls for Animal Food Accredited
Third Party Certification
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Confirm industrys primary role on food safety Risk-based and
flexible Burden commensurate with risk Address small business
issues Additional time for small farms, businesses, to comply
Extensive government, stakeholder Input
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Considers risk posed by practices, commodities, conditions
Science- and Risk-based Focus on identified routes of microbial
contamination Excludes certain produce rarely consumed raw Excludes
produce to be commercially processed Flexible Additional time for
small farms to comply Variances Alternatives for some
provisions
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Framework considers many factors associated with produce
farming community Examples include diversity of operations and
broad range of crops and practices Proposing integrated approach
that draws on past experiences Examples include CGMPs, HACCP, shell
egg regulation
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One way or another just about every producer is impacted by
this rule Scale and risk based Exemptions under Produce Rule Scale
and Risk based Exemptions under Preventative Controls
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Produce defined as fruits and vegetables Produce includes
mushrooms, sprouts, herbs and tree nuts Produce does not include
grains Some limitations on covered produce
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Produce for personal or on-farm consumption Produce not a Raw
Agricultural Commodity Certain produce rarely consumed raw Produce
that will receive commercial processing Farms with sales of $25,000
per year Qualified exemption and modified requirements
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1. Agricultural water 2. Biological soil amendments of animal
origin 3. Worker health and hygiene 4. Equipment, tools, buildings
and sanitation 5. Domesticated and wild animals Focus on 5
identified routes of microbial contamination Other requirements
Growing, harvesting, packing and holding activities
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Agricultural water: water used in covered activities on covered
produce, where water is likely to contact covered produce. Direct
contact Irrigation water Crop spraying Washing and cooling of
covered produce Cleaning food contact surfaces Hand during and
after harvest activities
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Overhead Irrigation : 235 GEC per 100ml Harvesting operations:
0 detectable GEC Dump tanks, cooling, ice, flumes, hydrocoolers
Hand Washing: 0 detectable GEC Drip Irrigation : Not Ag water as
defined by FSMA (Subject to FD& C act)
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Public Water System (SDWA) No Testing Private Well: Every 3
months Rivers or natural lakes: once every 7 days On farm man made
reservoir: monthly (if not subject to run off)
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Require treatment of agricultural water that you use if you
know or have reason to believe that the water is not safe and of
adequate sanitary quality for its intended use, including
requirements for treatment methods, treating such water, and
monitoring its treatment (proposed 112.43);
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Alternatives You may establish and use alternatives to the
requirements established in proposed 112.44(c) for testing water,
and taking action based on test results, when agricultural water is
used during growing operations for covered produce using a direct
water application method, provided you have adequate scientific
data or information to support a conclusion that the alternative
would provide the same level of public health protection as the
112.44(c) requirements and would not increase the likelihood that
your covered produce will be adulterated under section 402 of the
Federal Food, Drug, and Cosmetic Act.
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If you want to water your crops with overhead irrigation from a
pond, stream or river, you will test that water at least once per
week, per source throughout the growing season. No more wash tanks
or flumes in the pack shed, continuous or recirculated sanitized
flow only If you want to do something different show us a science
based alternative (FDA will not review just tell us you have
it)
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FDA defines a farms purpose as producing and preparing its own
raw agricultural commodities for commerce. Anything beyond that and
the farm becomes a facility (biosecurity act) and may fall under
the Preventive Controls Rule.
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FSMA will drive up farms annual costs. Estimates from $14,000
annually for a small farm. Significantly more if farm falls under
Preventative Controls FSMA will place new demands on NRCS FSMA may
drive some farms out of business and lead to increased development
pressure resulting in degraded water quality
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Educate our cooperators and partners Comment on the rules by
May 16 2013 Ask and hope we can get an extension through Dec 2013
Demand FDA perform an Environmental Impact Statement on the
rule