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The Northeast Center to Advance Food Safety (NECAFS) and the Center for Agriculture and Food Systems at Vermont Law School are seeking YOUR feedback to help gather a comprehensive list of legal questions and concerns, to allow their advisory group to prioritize and articulate critical questions for further research and clarity. Once researched, they will develop educational and outreach materials to extend this knowledge across the produce community.
The survey will remain open through December 14
th
.
All responses are anonymous; no identifying information will be collected. The survey will take between 5-20 minutes to complete.
Thank you for contributing, we highly value your input. Please forward to others and encourage participation. The results of this survey will directly inform the legal questions researched. If you have any questions, please contact
Elizabeth Newbold
, elizabeth.newbold@uvm.edu.
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The project is looking to hire a Grant Administrative and Communications Coordinator. The ideal candidate is a skilled mid-level coordinator looking to work on a small team in a fast-paced work environment. He or she would be interested in grants, agriculture, food safety, or membership-based organizations.
Those interested in applying should send a cover letter and resume to
employment@nfudc.org with "Grant Administrative and Communications Coordinator" in the subject line. References will be requested if selected for an interview.
Application closing date is Sunday November 25, 2018.
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FDA to Hold Four Public Meetings to Discuss Draft Produce Safety Rule Guidance
The public meetings will be held in different regions of the country to provide information and facilitate comment so that stakeholders can better evaluate and provide input on the draft Produce Safety Rule guidance. The information presented will focus on the various chapters of the draft guidance: general provisions; personnel qualifications and training; health and hygiene; biological soil amendments of animal origin; domesticated and wild animals; growing, harvesting, packing and holding activities on a farm; equipment, tools, buildings, and sanitation; records; and variances. Stakeholder panels will discuss various issues. There will be opportunities for questions and open public comment.
Although there is no current meeting planned in the Midwest, LFSC is considering other options for addressing this group's concerns. Growers interested in sharing feedback with LFSC should complete this online form.
Attendees are encouraged to register online to attend the meeting in person. For questions about registering for the meetings or to register by phone, contact Melissa Schroeder, SIDEM, 1775 Eye Street, NW, Suite 1150, Washington, DC 20006, 240-393-4496, Fax: 202-495-2901, email: EventSupport@Sidemgroup.com.
For general questions about the meeting, or to request special accommodations due to a disability, contact Juanita Yates, FDA, Center for Food Safety and Applied Nutrition, 240-402-1731, e-mail: Juanita.Yates@fda.hhs.gov.
First Public Meeting - Portland, OR
November 27, 2018, 8:30 am - 5:00 pm
The Hilton Portland Downtown
921 SW Sixth Ave.
Portland, OR 97204
November 16, 2018: Closing date for registration
Second Public Meeting - Anaheim, CA
November 29, 2018, 8:30 am - 5:00 pm
Doubletree Suites by Hilton/Anaheim Resort Convention Center
2085 S. Harbor Blvd.
Anaheim, CA 92802
November 16, 2018: Closing date for registration
Third Public Meeting - Albany, NY
December 11, 2018, 8:30 am - 5:00 pm
Hilton Albany
40 Lodge St.
Albany, NY 12207
November 23, 2018: Closing date for registration
Fourth Public Meeting - Atlanta, GA
December 13, 2018, 8:30 am - 5:00 pm
Embassy Suites Atlanta at Centennial Olympic Park
267 Marietta St.
Atlanta, GA 30313
November 23, 2018: Closing date for registration
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The
Technical Assistance Network , otherwise known as "TAN," are the people over at FDA whose job it is to help you understand the Food Safety Modernization Act (FSMA).
But, what if I tell you that the guidance TAN offers is not legally-binding? You may be surprised, but it's true. The FDA's own rules state that its guidance documents do not establish "legally enforceable rights or responsibilities." This may come as a relief, especially if TAN gives you an answer you don't like. Or, this may cause great anxiety, say if you like their answer and hope to rely on it. Either way, you are likely left utterly confused.
Don't worry. You're not alone. There are hundreds, maybe thousands of articles written, by lawyers, who are supposed to understand such things, expressing, debating, pontificating at great length about how confusing agency guidance and its "non legally-binding" nature is.
Legal pondering aside, there are two basic rules farmers should follow when considering TAN guidance.
Rule #1: If you're not going to follow the FDA's guidance, be able to show that your own approach will still get to the same goal of keeping food safe. This comes straight out of the FDA's own rules, which state, "You may choose to use an approach other than the one set forth in a guidance document. However, your alternative approach must comply with the relevant statutes and regulations." In other words, it is less important that you follow the FDA's guidance on how you keep the food safe, and more important that whatever methods you are using are effective at keeping the food safe. Backing up your methods with well-documented, scientific evidence of food safety effectiveness is extremely helpful.
Rule #2: Get the FDA's guidance in writing and get lots of it. While there doesn't appear to be any hard and fast rule within the FDA itself on this, there is the legal doctrine of equitable estoppel, which is just a fancy, lawyerly way of saying that it wouldn't be fair to punish a person for reasonably relying on what appeared to be another person's promise. In the context of food safety, this means that if the FDA offers guidance, and you rely on that guidance and it was reasonable of you to do so, you can't be punished for doing what they told you. But, you better make certain that you get that advice in writing, and the more written proof you have, the more reasonable it seems for you to have relied upon it. Letters, emails, website information, published guidance
documents - they're all your friend if you end up in a dispute.
By Sarah Vaile, Research Attorney, Farm Commons
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Farming inevitably presents produce safety risks, but increased knowledge and action can help farmers reduce liabilities and maintain successful operations. Previous blogs in this
series explained the biological risks that can occur due to bacterial growth or other pathogens, but because food safety hazards can take a variety of forms, it is necessary to include chemical and physical risks in the conversation.
The most common chemical hazards in farm operations are pesticides, sanitizers, insecticides, cleaning solutions and fertilizers. Label directions should always be followed when using chemicals as misuse could present a food safety risk. To prevent chemical contamination of foods, farmers should store all chemicals away from food preparation surfaces. In addition, farmers should educate themselves about risks that may already be present on their farm. Soil and water are places that chemical hazards can hide. In urban areas, testing soil can reveal potential hazards, since land may have previously been used for industrial processing or as a dumpsite. Water should also be tested for possible chemical contamination, which could be caused by run-off, industrial discharge, or incomplete treatment process.
By Liza Ayres, NFU Intern
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Interested in attending a PSA Training or Food Safety Field Day near you but don't see anything listed below?
Do you need
any FSMA, food safety or other supporting materials?
Want to have the Local Food Safety Collaborative speak or present at your conference this fall/winter?
Please complete the form below to make your request!
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UPCOMING EVENTS &
CONFERENCES
Windom, Minnesota
PSA Grower Training: 11/14
Portsmouth, New Hampshire
PSA Grower Training: 11/15
Kansas City, Missouri
Farmer Veteran Stakeholders Conference: 11/15 - 11/17
Morris,Minnesota
PSA Grower Training: 11/28
Louisville, Kentucky
Acres USA Conference and Trade Show: 12/4 - 12/7
Hutchinson, Minnesota
PSA Grower Training: 12/5
Gibsonia, Pennsylvania
PSA Grower Training: 12/11
Brooklyn Park, Minnesota
PSA Grower Training: 12/12
Watsonville, California
PSA Grower Training: 12/12
Abiquiu, New Mexico
PSA Grower Training: 12/12
Socorro, New Mexico
PSA Grower Training: 12/13
Saint Paul, Minnesota
PSA Grower Training: 12/17
Springfield, Illinois
Illinois Specialty Crops, Agritourism, and Organic Conference
PSA Grower Training: 1/8
Grand Junction, Colorado
PSA Grower Training and Farm Food Safety Plan Workshop: 1/9 - 1/10
Mankato, Minnesota
PSA Grower Training: 1/23
Cloquet, Minnesota
PSA Grower Training: 1/25
Little Rock, Arkansas
Southern Sustainable Agriculture Working Group Conference: 1/23 - 1/26
Greenley, Colorado
PSA Grower Training: 1/31
Saint Charles, Minnesota
Lancaster, Pennsylvania
Pennsylvania Association for Sustainable Agriculture Conference: 2/6 - 2/7
PSA Grower Training and Food Safety Panel
Andover, Minnesota
PSA Grower Training: 2/20
Farmington, Minnesota
PSA Grower Training: 3/20
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