Growers: Voice Your Concerns

Sep. 3, 2013



(Originally posted 8/30/13 at

WOOSTER, Ohio -- Produce farmers have an extended period to comment on changes that the U.S. Food and Drug Administration will require in its proposed food safety rule, and an Ohio State University food safety program coordinator is encouraging them to take advantage of the opportunity.

"The FDA seems to be listening to the grower quite a bit, especially the smaller grower," said Lindsey Hoover, who started in her position earlier this year. "They want to know what the concerns are."

The food safety program is part of Ohio State's Produce Safety Team, part of OSU Extension and the Ohio Agricultural Research and Development Center, the outreach and research arms of the College of Food, Agricultural, and Environmental Sciences. 

The proposed produce safety rule, part of the 2011 Food Safety Modernization Act (FSMA), was issued in January, and the comment period has been extended twice. Currently, comments are due by Nov. 15 and can be made by going to and searching for FDA-2011-N-0921.

Comments may also be mailed to Division of Dockets Management (HFA-305), Food and Drug Administration, 5630 Fishers Lane, Room 1061, Rockville, MD 20852. All submissions must include the agency name and docket number: FDA-2011-N-0921 and RIN 0910-AG35.

Produce safety is just one area covered under FSMA. Other areas include the safety of imported foods and preventive measures for food manufacturers, processors, packers and storage facilities.

Detailed information about FSMA and the proposed produce safety rule is available at Hoover says growers may find the "For Farmers" section especially helpful, which includes "Fact Sheets on subparts of the proposed rule." The PDF files of the fact sheets are easy to print out and review, she said.

Hoover has heard several concerns from farmers regarding issues in the proposal, including:

  • Expenses and resources required related to water testing.
  • Expenses and resources required related to recordkeeping.
  • The nine-month time frame between spreading of untreated manure on fields and harvest. The time frame currently used in organic production, for example, is 90 to 120 days, depending on the crop. Farmers in the Amish community are particularly concerned about the prolonged time frame in FDA’s proposal, Hoover said.

Small farms -- those averaging sales of less than $25,000 a year -- are exempt from the rule, Hoover said. However, as always, any farm selling food for public consumption is covered under the federal Food, Drug and Cosmetic Act, which states that all producers are responsible for providing safe, unadulterated food to consumers.

For information about Good Agricultural Practices, or GAPs, for fruits and vegetables, Hoover recommends the Produce Safety Team's website,

In addition, Hoover recommends the website of the Produce Safety Alliance, a partnership between Cornell University, the FDA and the U.S. Department of Agriculture,


Writer: Martha Filipic, (614) 292-9833,

Source: Lindsey Hoover, (330) 202-3555 ext 2918,