An Update and a Request from the Pennsylvania Association for Sustainable Agriculture (PASA)

The first few days of 2013 brought some extraordinary events that will likely affect the sustainable agriculture movement for many years to come.

First there was the debacle on New Year’s Day when we woke up to find that the so-called “fiscal cliff” deal in Congress, hammered out in the middle of the night, also included a 9-month Farm Bill extension with some curious features. While retaining the subsidy programs for commodity crops, essentially all of the more-or-less sustainable provisions of the bill were missing in the extension. This is an unprecedented event – as just about everything happening in Washington DC is these days – and the situation will remain this way unless and until a new 5-year Farm Bill (or additional extension) can be passed with some of these provisions that sustainable ag advocates had fought many years to establish are restored. Let’s just say, we’re not holding our breath, but will let you know what’s happening as the situation unfolds.

But another huge event that happened, just a week ago today, was the long-awaited release of new food safety regulations by the FDA, representing almost 2,000 pages of material that must be absorbed, understood and responded to by public comment within 120 days. These regulations are coming two years after the new Food Safety Modernization Act was passed and signed into law, and a year later than required by the law itself – the long delay was almost certainly a result of the recent presidential election. There are in fact still some parts of the new regulations to be released presumably later in 2013.

The two main pieces of regulation are titled respectively as the Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption, which is rather self-explanatory, and the Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventive Controls for Human Food, which is more easily understood as the rules for food processing facilities. The full text of each is available on the PASA website at the link provided. Before anyone gets frustrated by the length of these documents, please be aware that the bulk of each is in the form of a preamble, and the actual proposed rules are relatively short by comparison.

PASA has been involved in this process since the very beginning – in the spring of 2009 – and we’re not about to back out of it. However, now that the “rubber is hitting the road” so to speak, we’re going to need the help of many of you out there to do our jobs thoroughly and most effectively. Namely, we need some of you who will be directly affected by these rules to read them and give us some feedback in the shorter term, and as the comment period comes to a close in the springtime, we’ll need many others of you to join us in writing relevant comments for submission to FDA.

Brian Snyder, Executive Director

(you can view Brian’s entire letter here.)

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