Letter to Margaret Hamburg, Commissioner of the FDA - Regarding New Food Safety Rules

Letter

Dear Commissioner Hamburg:

I write to convey concerns from Colorado agricultural producers regarding the Food and Drug Administration's ("FDA's") proposed rules under the Food Safety Modernization Act ("FSMA"). I also write to invite you to Colorado to hear directly from producers about how the proposed rules could affect their work.

The FDA's recent decision to review its proposed rules on spent grains was greatly appreciated by small brewers and producers in Colorado who believed that they would have the unintended consequence of stopping the transfer of spent grains to producers.

We have heard similar concerns about the practicality of following the proposed rules from other types of producers in Colorado. Specifically:

Onion producers have noted that the proposed rule does not correspond to the risk levels for their crop, particularly the "recreational use" water quality standard and the prohibition on the use of wooden containers;
Fruit and vegetable farmers have concerns about the proposed rule's water quality standards and compliance; and
Organic producers have misgivings about the proposed rule's restrictions on the use of soil amendments.

Colorado producers are very supportive of FSMA and are committed to working with the FDA to create a regulatory framework that ensures a healthy food supply and reduces risk for consumers. I would nonetheless encourage the Agency to reexamine the proposed rule in light of the views outlined above. I also hope that you'll visit Colorado. I believe that the Agency's process could benefit greatly by hearing the perspective of Colorado producers.

Thank you for your consideration, I look forward to hearing from you.

Source