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Letter From the Editor: Praise for Procrastination

Once while taking a final examination in college, I was introduced by the professor as a new student in the class. Being just a little slow to get to classes was the sign of a procrastinator. I’ve always fought against being one, but I’ve come to accept that we are a nation of procrastinators.

That national trait was on display this past week when the U.S. Food and Drug Administration (FDA) gave everybody an extra week to comment on the produce and preventive control rules for implementing the Food Safety Modernization Act (FSMA) of 2010.

Many were obviously counting on FDA putting additional time on the comment clock after the Regulations.gov website started sputtering on the eve of the original Nov. 15 deadline. But who would have guessed that almost another 2,000 would comment on the produce rule and almost another 1,000 on the preventative controls rules — and would make the extended deadline?

Who would have guessed that so many would take it down to the wire? Final counts are 13,461 comments on the produce rule and 6,181 on preventive controls. A crush of comments also came in just ahead of the original Nov. 15 deadline.

Much of the credit for generating this response — albeit at the final moment — goes to the National Sustainable Agriculture Coalition. Relatively late in the process, the National Association of State Departments of Agriculture, joined by the United Fresh Produce Association, came up with the strategy of persuading FDA to issue a second set of these rules.

But it was left to NSAC to pull the cord on a truly grassroots campaign to get the job done. This organization did something fairly rare in that it educated and activated its members to make specific criticism without challenging the basic underpinnings of the FSMA.

This means FDA is going to have its work cut out for it, as many of those nearly 20,000 comments it has to review are going to be from serious players. And we procrastinators do know how to pour it on. NSAC’s own comments on the produce rule, turned in on the last day, run 180 pages.

“NSAC’s comments on the proposed regulations reflect the concerns of sustainable and organic farmers and food businesses that are pioneering farming practices and food supply chains to increase consumer access to healthy food, sustain the environment, and create new economic opportunities,” said Ariane Lotti, the group’s assistant policy director. “NSAC’s recommendations are aimed at improving the regulations so that they advance food safety goals while simultaneously supporting sustainable agriculture and food systems. As proposed, the regulations will severely restrict the use of sustainable farming practices, inhibit diversification and innovation in farming and short supply chains, and fail to provide workable, affordable options for family farmers.”

“The proposed regulations fail to meet the requirements that Congress set forth in FSMA for a flexible approach that reflects different risks at different scales and supply chains,” she added.

Mike Taylor, who heads up the food side of FDA, has been doing his own “listening tours” of farms and produce businesses. Now he and his people have much to wade through that comes from the folks who will be most impacted by these rules.

“NSAC is grateful for the agency’s outreach during the comment period, and looks forward to continuing to work with FDA to craft flexible, science-based regulations that support agricultural diversity and a healthier food system,” Lotti said. “Supporting thriving local and regional food systems and ensuring a safe food supply are complementary, not competing, goals.”

As all of us procrastinators know, in the end no one remembers when the work was turned in or who was in attendance at what class. It’s the outcomes that are important. And, for the record, I got an A in that class.

© Food Safety News
  • pawpaw

    Dan,
    I’m also a procrastinator in certain areas. Trick is knowing which areas are appropriate, which not.
    There’s a natural rhythm for many farmers, working outdoors when it’s light and temps more enjoyable. During the shortening days of fall, we often work during a ‘harvest moon’ to bring crops in.
    Many farmers also recruit, hire, train and manage seasonal employees. Once crops have been grown, harvested, sold/stored, some workers move on. Then farm managers can breathe easier and turn their sights toward education and advocacy.

    We have a culture of reading with our feet by the fire, late fall and winter, with new seed catalogs in hand. Most of our training meetings, regional and national, are also held fall and winter.

    Our regional meeting to discuss FSMA was held early Nov, and we were provided with addresses to write/print letters and mail them in. Encouraged to submit comments on proposed regs specific to our farms. Even then, we were warned of the difficulty of posting comments at FDA, the hours of delays by one participant before finally getting through. Hence the handout of pre-printed envelopes, to mail in hand-written responses. I’m one who read the 100s of pages in the proposed FSMA rules, but benefitted by hearing/seeing thoughtful responses from farmers/processors working under different rules that appear to meet FSMA goals. But in certain cases are much more farmer friendly, being developed and revised by farmers and their public/private partner advocate and agencies. Such as GAPs and NOP (USDA Organic Regs).

    So some of us, when finally catching our breath, sat up and paid attention. FDA appears to be asking for help in crafting scale-appropriate regs, which would cover the vast majority of fresh produce.

    And as you wrote, work completed just in time is still work on time. I’m a pollworker, and if a voter makes it in line by the time polls close, we are obligated to count their vote. In limited but appropriate circumstances, voting hours may be extended, and all those votes count as well.

  • farmber

    WOW — 20,000 Comments — and more in the mail.

    FDA has A LOT of important reading; digesting — and complete rewriting to do!!!

    And — they have to GET IT RIGHT.

    A whole diverse lot of groups including NSAC, the National Association of State Departments of Agriculture, United Fresh Produce Association, etc, ETC are calling for FDA to issue a completely new Second Set of rules — NOT an Interim rule — with another whole Comment period…