The Virginia Association for Biological Farming (VABF) offered the attached comments on the Food and Drug Administration’s (FDA) supplemental proposed rules on Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption (Produce Rule) and Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventive Controls for Human Food (Preventive Controls Rule).
On November 11, 2013, VABF submitted extensive comments on the first Proposed Rules for Produce and Preventive Controls. We appreciate FDA’s efforts to make the Rules more practical for small and medium scale produce farmers. At the same time, upon review of the supplemental proposed rules, we remain concerned that several provisions in the Re-proposal could impose unwarranted burdens on our farmer members and other family farms across the US, and/or create barriers to the development and expansion of local, sustainable food systems. We address these issues in the attached pages.
