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Provide Your Feedback on FDA Regulations That Could Impact Local Producers

I just finished submitting my comments on and to my legislators on FDA regulations that are under consideration right now and could dramatically impact small-scale providers of locally grown and produced foods.

Read the full details of the regulations and their potential impacts here on the Food Renegade blog.

I adapted the language on that site with my own comments and submitted it to at these links:

On-Farm Produce Rule:!submitComment;D=FDA-2011-N-0921-0199

Preventitive Controls/HARPC Rules:!submitComment;D=FDA-2011-N-0920-0188

I then sent the same comments to my federal legislators asking them to take my comments into account if they play any part in the process of finalizing such regulations.

Please consider doing the same thing. You can use my comments below:

As a consumer of locally produced food from farms in my area of the Eastern Shore of Maryland, I urge the FDA to address the following issues in the proposed FSMA rules. It is so important to make it EASIER for these small farms to operate, rather than throwing up hurdles and roadblocks.

Industrial agriculture lays waste to land that could feed local populations so much more easily, with less damage to the environment, and healthier food options for consumers. Save the onerous paperwork and inspections for the industrial-scale operations that are poisoning our land and our food with pesticides and GMO crops. Let the smaller-scale producers flourish.

Tester-Hagan “qualified exemption” in both the Produce Rule and the Preventive Controls Rule:
The gross sales test to qualify for the Tester-Hagan provision should be based on sales of food that is subject to FSMA, whether the produce standards or the preventive controls rule. Sales of food that would not be regulated under FSMA should not be included.

The FDA should not rush the process of revoking a producer’s Tester-Hagan exemption. The agency has other mechanisms it can use if there is an immediate threat of foodborne illness.
a) The FDA should be held to specific evidentiary standards before it can revoke a farmer’s or food facility’s Tester-Hagan exemption.
b) A farm or facility that is exempt under Tester-Hagan should be given at least 90 days to submit evidence and defend its exemption if FDA seeks to revoke it.
c) If the exemption is revoked, the farm or facility should have at least two years to come into compliance with the FSMA rules.

On-farm Produce Standards Rule:
The FDA’s approach to traditional farming methods, such as diversified livestock-crop farms, the use of working animals, and the use of biological soil amendments, is fundamentally flawed. The agency should not restrict these sustainable methods of farming without data showing an actual, verified increased rate of foodborne illness; the simple fact that these methods include diverse microbiological communities is not a sound scientific basis for restricting them.

The waiting period between applying manure and harvesting the crop should be no more than 4 months, and there should be no waiting period between applying compost and harvesting the crop. The excellent track record for safety on organic farms shows that this standard is sufficient.

Compost teas and other biological inoculants, including normal additives such as molasses, should be treated the same as compost.

Water testing should not be required more often than once a month, and farmers should be able to test less frequently after establishing the safety of their water source through consecutive negative tests. In addition, farmers should be given the option to test for pathogens, rather than having to treat or stop using the water that tested positive for generic e. coli.

The provisions on wildlife and domestic livestock need to be clarified to protect farmers who use biologically diverse farming from field inspectors using their discretion to require measures such as fencing or destruction of habitat.

Preventive Controls and HARPC Rule:
“Very small facilities” should be defined as being under $1 million in total annual sales, adjusted for inflation. Imposing HARPC requirements on businesses smaller than that is unnecessary and overly burdensome.

Any requirement for “supplier verification” should not prevent a facility from purchasing foods or ingredients from farms and facilities that are exempt from the regulations under the Tester-Hagan provision or other exemptions.

Low-risk activities conducted by a farm using its own products, such as making jams, grinding grains, or dehydrating vegetables, should not be subject to these regulations.

Low-risk activities, when conducted off-farm or by multiple farms working together, should not be subject to the same requirements as high-risk processing activities. The requirements should address both the scale of the operations and the level of risk of the activity.


The Haul: Field Trip Edition

bison2I used up the rest of my bison meat a couple of weeks ago, so I ventured out to SB Farms in Hurlock today to pick up some more. I bought ground bison, a chuck roast and some jerky–enough to get me through until the open-air Easton Farmer’s Market reopens on April 13. Farmer Bill Edwards was kind enought to give me a little booklet with recipes, including one for bison bbq, which I intend to make out of the chuck roast. I took some photos while I was out there:


The resident greeter at the farm.


Two bald eagles have a nest on the farm as well.


In other haul news, Eating Out of the Box has started up again in Easton and they now offer a la carte options! This week, I ordered baby carrots and two kinds of breakfast sausage. I supplemented this with kale, lettuce and salad turnips that I bought earlier this morning from Provident Organic Farm’s stand in front of Rise Up Coffee.

The Haul: Yes-Even-in-February Edition

2013-02-22 22.17.20

That’s right, all through winter, I’ve been able to get fresh, local produce thanks to a couple local farms and a CSA. This morning, I went to a small farmer’s market that’s open every Saturday morning starting at 10 in front of Rise Up Coffee here in Easton. I stocked up on a lot of greens as that’s what’s available this time of year. I’m on a mission to get back to my pre-holidays self and so I’m back to basically eating meat, veggies and a little bit of fruit. I have a huge pile of greens with almost every meal.

This week, I bought:

  • Chard (I really wanted spinach, but this was the next closest thing)
  • 2 kinds of lettuce
  • Kale
  • Carrots
  • Sweet Potatoes

In the upper-right corner, you may have spied the topic of my next blog post. I didn’t get it at the farmer’s market this morning — those aren’t grown locally, of course.

The Haul: Christmas Clam Edition

DSCN4181Yesterday, I returned to the Easton open-air farmer’s market for the first time in a few weeks. It’s smaller now, but it was still hopping. Here’s what I bought:

  • Maple sausage
  • Sweet onion
  • Garlic
  • Fuji apples
  • Chamomile tea
  • Christmas wreath

Then I stopped by the seafood market and picked up a dozen littleneck clams, a pound of wild salmon and a lemon. I found this recipe for steamed mussels and clams. I didn’t have a lot of the ingredients (including the mussels), so I made a lot of substitutions.  I had to make my own cocktail sauce, but didn’t have horseradish, so I added hot chinese mustard. The sauce ended up pretty ketchup-y, but was still good. I don’t usually have butter in the house, so olive oil stood in for that in the other sauce. The dish was really pretty and tasted pretty good too. The juxtaposition of the red and green sauces is perfect for this time of year.



There is a new type of farmshare in town that is really neat. Eating Out of the Box has both medium and large boxes on offer and they gather produce from various farms in the area. I get mine delivered. The boxes become available in the middle of the week, which is nice because that’s about the time I run out of fresh stuff from the weekend market. I’ve tried it twice and gotten some really good stuff including lemongrass, Asian pears and all kinds of greens. This week, joi choi arrived (a larger version of bok choi).

The thing I love about farmshares is that you get ingredients you wouldn’t normally buy and so you learn to cook new dishes. I’m still trying to find something to do with the huge daikon radish that arrived this week.

The Haul: Charting New Territory

Today’s haul from the farmer’s market:

Blueberries! Local, of course.

Local onions

Local garlic

Local kohlrabi

Local garlic scapes

Not shown, eggs and olive bread, plus a spearmint plant I’ve already potted out back.

I’ve never cooked kohlrabi before, but was intrigued when a coworker mentioned she’d be receiving some in her farmshare this week. I don’t know how I’m going to prepare it yet, but I think I’m going to go Indian.

The garlic scapes just looked too fun to pass up (never cooked them either):

Saturday Finds

There are drawbacks to relying on farmer’s markets as your main source of food. My Saturdays usually revolve around shopping for and cooking food. Our open-air farmer’s market is only open on Saturday mornings and that’s also usually the only time I can get to the Amish market and the seafood market. If I don’t get to the markets on Saturday morning, I don’t get fresh food for that week. So even on mornings like today’s, when I’m tired and not feeling well, I still need to get out there and shop.

The benefits of shopping this way far outweigh the drawbacks, however. One of the benefits of participating in a CSA is that you get to try food you probably wouldn’t bother to buy if it were left up to you. I am not participating in a CSA this year, but don’t want to miss out on that benefit. Today, I decided to try a vegetable that I’ve never cooked for myself before: rainbow chard.

I picked up scallops at the fish market as well and decided to pair the two for dinner tonight. I found relatively simple recipes to prepare each one. Here was the result:

I have had chard at restaurants before, but usually not all on its own. I find the flavor to be a little too strong for my liking, so I’ll probably incorporate the leftovers into a pasta dish or something. I hope that will tone down the flavor a bit.

And no, I didn’t eat all of those scallops in one sitting. I wanted to though.

The Week in Food News

Wow, what a crazy (but fun) week I had! I had no time to cook, let alone post. I did try to save some interesting links that I found though:

Why Buy Local? — this infographic demonstrates the problems with the current consumer system through its impact on the environment and the economy. It says that the average carrot travels more than 1,800 miles to become part of a meal in the U.S. Not mine. Mine come from less than 100 miles away because I buy them at the local farmer’s market. (Via

Farmers are embracing social media. This is great news. Before I started buying from almost every local farm that now supplies my food, I connected with them first on the Internet. (Via

Think it’s more expensive to shop at a farmer’s market? Think again. (Via

Calorie bombs in/near Baltimore. (Baltimore Sun)

Small yard? Learn about square-foot gardening. (College Park Patch)

Grilled peanut butter and banana split sandwich. You’re welcome. (Cooking Light)

A cookbook to help you deal with all of those new-to-you foods in  your farmshare. (