NACD Weighs In on Proposed FDA Rule
(NAFB)--The National Association of Conservation Districts has submitted comments on the Department of Health and Human Services, Food and Drug Administration advanced notice of proposed rulemaking on Standards for the Growing, Harvesting, Packing and Holding of Produce for Human Consumption. NACD President Earl Garber says conservation districts are committed to the shared goal of improving food safety through conservation efforts in a sustainable and accountable manner that considers current best management practices as well as federal guidelines. He says NACD applauds FDA for its commitment to food safety - but has concerns about the rule’s potential impacts on land operators and the agriculture industry in general. NACD believes the current specifications of the rule would lead to higher costs and a greater burden on producers. The group says it would also have broader implications for efficiency and competitiveness of the farming industry as producers struggle to comply with certain strict rules. NACD also finds possible adverse effects to voluntary on-farm conservation and land management practices where NRCS Technical Standards are currently in place relating to agricultural water, biological soil amendments of animal origin and wildlife habitat.
As written - New Hampshire Association of Conservation Districts President Roger Noonan says the rule would place a heavy regulatory and financial burden on all farms - but especially small and very small farms. Noonan notes these farms provide important wildlife habitat and maintain or improve local water quality. He says the high costs of compliance could drive these farms out of business - ultimately hurting the economy and the environment.
NACD supports the decision for FDA to perform an Environmental Impact Statement on this rule before implementation. Garber said conservation districts can provide invaluable technical assistance during the realization of this rule. He says they look forward to demonstrating to FDA the current conservation practices already employed across the landscape - and encourage FDA to issue a draft proposed rule to provide additional opportunity for stakeholder input.