Food Safety Overview - Organic Trade Association
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Food Safety Overview


Food safety is at the forefront of consumers’ food concerns. The food recalls issued in recent years, along with pressure from consumer groups and constituents, caused Congress to take up legislation to ensure the safety of America’s food supply.

On January 4, 2011, President Obama signed into law the FDA Food Safety Modernization Act (FSMA). The Act amends the Federal Food, Drug, and Cosmetic Act with respect to safety of the food supply and is aimed at helping the U.S. Food and Drug Administration (FDA) prevent food safety problems by shifting the focus from response to contamination prevention. This amendment is the most significant reform to food safety law in 70 years. In addition to giving FDA new enforcement authorities and new tools for managing imported foods, the Act requires food facilities to identify potential food safety hazards, and to develop and implement preventive control plans. It also requires FDA to establish fruit and vegetable harvesting standards.

Read more about FSMA

FDA Releases Proposals for Two Key Rules Under FSMA
Two years later, FDA has released for public comment its proposed rule to establish science-based standards for growing, harvesting, packing and holding produce on domestic and foreign farms. A proposed rule for preventive controls for human food was published at the same time. These are two of the proposed rules that are key to the preventive food safety approach established by FSMA. 

View the home site for the new rules

View OTA’s summary presentation on the two new proposed rules

View OTA’s summary presentation on the two new proposed rules

actionNow is the time to make your voice heard. FDA is actively seeking comments from the public, and submitting an individual comment is the #1 most effective way to have an impact! 

Submit your comments today!

The Preventive Controls for Human Food Rule would require food companies—whether they manufacture, process, pack or store food—to put in place better controls to minimize and reduce the risk of contamination. The rule proposes each covered facility to prepare and implement a written food safety plan to to identify potential hazards, similar to Hazard Analysis and Critical Control Points (HACCP) systems that are required by FDA for juice and seafood.

View the Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventive Controls for Human Food Proposed Rule. 

View OTA’s Summary of the Preventative Controls for Human Food Rule

View OTA's Presentation on draft comments on the Preventive Control Rule

View OTA's Talking Points on the Proposed Preventive Control Rule

View OTA's Final Comments on the Preventive Controls Rule

The Produce Safety Rule would require farms that grow, harvest, pack or hold fruits and vegetables to establish and follow science-based standards for the safe growing, harvesting, packing, and holding of produce in its raw or natural (unprocessed) state. FDA proposes to set standards associated with identified routes of microbial contamination of produce, including: (1) agricultural water; (2) biological soil amendments of animal origin; (3) health and hygiene; (4) animals in the growing area; and (5) equipment, tools and buildings. The proposed produce rule provides growers flexibility in their approach to on-farm food safety, so that food safety practices being taken by farmers can be appropriate for the scale of production and type of agricultural practices being used.

View the 
Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption Proposed Rule. Also referred to as the “Produce Safety Rule.”

View OTA’s Summary of the Produce Safety Rule

View OTA’s Summary of Who Would be Covered by the Rule

View OTA's Talking Points on the Produce Safety Rule

View OTA's Talking Points on the requirements for compost and manure

View OTA's Presentation on draft comments on the Produce Safety Rule

View OTA's Final Comments on the Produce Safety Rule

View OTA's Survey of Organic Producers on the Use of Compost and Manure

FDA is proposing that the requirements be effective 60 days after a final rule is published in the Federal Register. Recognizing that small and very small businesses may need more time to comply with the requirements, compliance dates would be phased in based on business size.

Comments on the proposed rule are due within 120 days of the rule’s publication in the Federal Register: November 15, 2013

How do I comment on the proposed rules?
These are proposed draft rules and not final regulation. Stakeholders are encouraged to comment on aspects of the rules they object to or do not understand. Comments must be submitted by November 15, 2013.

Sample letters make it simple to weigh in
Use OTA’s sample letters as a start for your own comments. The italicized portions at the beginning will help personalize your comments. You may refer to OTA’s comments if you would like to re-emphasize our primary concerns and recommendations.

Instructions on submitting comments to FDA
OTA has outlined
detailed instructions for submitting comments to FDA Online, or written comments via U.S. mail. Click on these direct links to post comments on FDA Online:

Produce Safety Rule:
Preventive Control Rule: FDA-2011-N-0920.

All submissions received must include the Agency name and Docket No. FDA-2011-N-0921 and Regulatory Information Number RIN 0910-AG35 for this rulemaking.

The Preventive Controls Rule for Animal Feed and Pet Food

If you are a manufacturer of organic animal feed or pet food, the U.S. Food and Drug Administration’s (FDA’s) proposed food safety rule will likely impact you. The deadline for submitting comments to FDA on proposed rules implementing the animal feed and pet food provisions of the Food Safety Modernization Act (FSMA) was Monday, March 31. Under the proposed Preventive Controls for Food for Animal Rule, facilities that manufacture, process, pack or hold animal feed and pet food would be required to develop and implement a formal plan for identifying and preventing foodborne illness, as well as establishing plans for correcting problems. The rule would require facilities to follow current good manufacturing practices that protect against contamination.

OTA Food Safety Task Force
In April 2009, OTA launched a Food Safety Legislation Task Force to track and analyze numerous pieces of pending U.S. food safety legislation for impact on the organic industry, and to recommend appropriate courses of action. During the drafting of FSMA, OTA successfully lobbied Congress to include language in the law that would prevent requirements from contradicting organic methods and materials.

In January 2013, OTA reconvened the Food Safety Task Force to analyze the two proposed rules in order to inform OTA's comments that will be submitted to FDA on behalf of membership. OTA invites members to take this opportunity to provide critical feedback on how the proposed food safety practices may impact your operations.

View OTA's Final Comments on the Preventive Controls Rule for Animal Feed and Pet Food

OTA At Work For You
Final countdown to Food Safety comment deadline – Take Action Now!

FDA Food Safety Public Meeting - OTA Oral Comments

The Organic Report Food Safety Update

Big Week For Organic and Food Safety

Read more about OTA’s work on the food safety legislation

Where can I go for more detailed information?
FDA’s website is frequently updated with new information:

Produce Safety Rule:

Preventative Control Rule:

Please contact
Gwendolyn Wyard, OTA’s Regulatory Director of Organic Standards and Food Safety, if you have any questions or if you would like to provide feedback on the proposed rules.

2014 Annual Fund

Research and Promotion 2012