Help FDA develop reasonable, science-based rules regarding manure by completing this Farmer Survey
About this survey: Virginia Association for Biological Farming (VABF) and the National Sustainable Agriculture Coalition (NSAC) are looking for information to better understand how farmers are using untreated or raw manure on their farms. We’re asking for this now because the Food and Drug Administration (FDA) is currently gathering information regarding on-farm use of manure, as well as existing scientific research on manure use and food safety, with the goal of developing reasonable, science based guidelines for time intervals between a manure application and subsequent produce harvest.
The fact that FDA is even asking for this information is the result of a huge victory that NSAC, VABF, and the broader sustainable agriculture community achieved during the Food Safety Modernization Act (FSMA) proposed Produce Rule comment period. FDA had proposed rules that would have severely restricted the use of manure as a source of nutrients and organic matter, by requiring a nine-month waiting period between applications of manure that has not undergone documented high-temperature composting and the next produce harvest. Comments from VABF and farmers like you demonstrated to FDA that their proposed rule did not adequately account for regional variations in climate and growing seasons, or the diversity of manure management and production practices that farmers use across the country. As a result, FDA agreed to go back to the drawing board. This request for information by FDA is the first step in that process.
FDA has committed to doing a full risk assessment that will look at pathogen survival while considering different agricultural and ecological conditions (e.g., soil types, application methods, geographic locations, climatic factors) and considering different time intervals between when manure is applied and the crop harvested. The risk assessment will eventually inform FDAs next proposed standard setting a required minimum application interval for raw or untreated manure. To make sure this risk assessment, and the final standard, fully accounts for the diversity of ways in which farmers use biological soil amendments, particularly raw or untreated animal manure, we are asking for your participation in the survey below.
The information you submit will remain anonymous unless you choose to identify yourself. The responses will be aggregated and used by VABF and NSAC in our comments and ongoing dialogue with FDA to ensure FDAs new food safety standards work for sustainable agriculture.
You can find out more information on FDAs risk assessment process on NSACs website.
Please complete this survey by MAY 20 so we can aggregate the responses and integrate them into the comments NSAC will provide to FDA. We recognize this is a busy time of a year for you, and we apologize for asking for responses in such a short time window. The questions below shouldn’t take more than 20 minutes! Your input is so valuable to this process. Thank you!
You can complete the survey online here.
Or, you can complete a paper version of the survey (Download in Word or Download in Adobe Acrobat) and mail it to:
National Sustainable Agriculture Coalition, 110 Maryland Ave. NE, Ste. 209, Washington, DC 20002
