FDA food and safety

The Rhode Island Farm Bureau, in its comments, urged the FDA not to adopt the rules, which it says will “drive a lot of farmers out of business.”

The Wisconsin Farmers Union argued that the proposed “rules could potentially have devastating effects on small and medium sized produce farmers.”

Third, members of the public health community should be commended for criticizing the proposed rules.

The comments of Sam Dickman, a third-year medical student at Harvard University, typified some of the public-health community’s welcome opposition to the proposed rules.

“I am very concerned about the ways that the FSMA rules as currently outlined will threaten the viability of small to midsize family farms and new farmers,” writes Dickman.

Dayna Green-Burgeson, a farmer and registered dietician, commented about her concerns over “the impact that FDA’s proposed FSMA rules will have both on my ability to farm and on my patient’s access to locally grown, healthy and tasty fruits and vegetables at a reasonable price.”

Jane Pearson, a Washington State physician, noted in her comments that she’s “concerned that these additional rules will make it more difficult for [local farmers] to continue supplying our community with healthy food and the support they give to creating healthier environments for us locally.”

And Joseph Kohn, a doctor and farmer, commented that he’s “deeply concerned about the impact that FDA’s proposed rules under FSMA would have on my food business and the farms that I buy food from.”

Finally, I’d be remiss if I didn’t note that opposition to the proposed rules is not universal.

Some commenters view the proposed rules quite differently than I do. Take, for example, a group called the Center for Progressive Reform.

“Not only will it substantially prevent many of the wide-ranging harms associated with contaminated produce,” writes the CPR, commenting in support of the proposed produce rule, “but it will do so at a reasonable cost[.]”

I suppose that’s true, if by “substantially prevent[ing]” harms at a “reasonable cost” the CPR means spending hundreds millions of dollars in order to decrease foodborne illness by somewhere between zero and two percentage points.

So will the FDA adopt these costly rules and crush small farmers? Only time will tell.