Don’t Let FDA’S Proposed Traceability Rule Jeopardize Small Farms

When it comes to U.S. agriculture regulations, one size does not fit all. That was the message that Community Alliance with Family Farmers (CAFF) and thousands of family farmers delivered ten years ago when the Food & Drug Administration (FDA) began hashing out the new Food Safety Modernization Act (FSMA). Had it not been for that advocacy, FSMA would likely have regulated small family farms the same way it regulates larger corporate growers, and would have buried small farms beneath paperwork.

FDA needs to hear the message again. Speak up by February 22!

The FDA is again proposing burdensome new requirements that would apply to almost everyone involved in the food system, including farms, cottage food operators, and restaurants. For producers of foods that FDA lists as “high risk,” the proposed rule imposes extensive recordkeeping requirements. These would include electronic spreadsheets; GPS coordinates for where the foods are grown; and the location, date, and time that the food is harvested, cooled, packed, shipped, or used as an ingredient in another food. For big businesses supplying complex, global markets perhaps this is reasonable. But for a family farm with limited means, few employees, and hardly an hour to spare, these regulations are a recipe for disaster. 

Farmers, businesses, and individuals who care about healthy local and regional food systems need to speak out about the FDA’s unfair proposed rule on recordkeeping in the food supply chain. FDA is taking public comments on the proposed rule, and this is your chance to tell the agency how damaging these requirements could be for your farm, your food business, and your local food community. The steps below will help ensure that FDA reads your comment. 

Step 1

Determine how your farm, business, or local farms you depend on may be affected by the proposed Traceability Rule. Any farmer who grows fresh produce that is eaten raw may be affected. The National Sustainable Agriculture Coalition has more information.

What the New FDA Rule Means for Farms: Part 1

What the New FDA Rule Means for Farms: Part 2

In short, if you grow common crops such as lettuce, tomatoes, and melons, your farm will likely be required to follow new recordkeeping requirements unless 100 percent of your sales are direct to consumers. If your farm sells to food hubs, restaurants, retailers, wholesalers, or other businesses, then it’s likely that you’ll have to comply. 

For more information, read the full text of the proposed traceability rule.

Step 2

Use our template to customize your comment. Either copy and paste the text into a new document or click “File” in the upper-left corner and select “Download,” choosing your preferred format. We recommend Microsoft Word. Revise the highlighted text areas to explain who you are and how this unfair recordkeeping rule would affect you. Delete any unnecessary text that you don’t want in your comment.

Step 3

Submit your comment. You can copy and paste text directly into the comment box on the website or upload your comment as an attachment.

All information in the comments will be made public, including your name and contact information you provide.

Step 4

Share your comment with your members of Congress so they understand what the FDA is attempting. CAFF has a site to help you find contact information for your representatives and senators here.

The comment deadline is February 22, 2021, at 11:59 p.m. Eastern Time.


This article was originally published as a blog on the CAFF website on February 10, 2021.