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Raw manure on your fruits and veggies? FDA seeks comments

Federal officials want input on one of the loose ends they left dangling when they published the new produce safety rule this past fall — the use of raw manure in fresh produce growing operations.


Pushback from industry led the U.S. Food and Drug Administration to hold off on including specific manure regulations in the produce safety rule, which was made public in November.

The agency was under a federal court order to finish the rule by Halloween 2015, but FDA officials said they lacked adequate scientific data to nail down the “biological soil amendments” portion of the rule.

“The agency is concerned about the potential of raw manure and other such amendments to contain disease-causing bacteria. Growers see raw manure and other such amendments as an effective way to enrich the quality of their soil,” according to an FDA news release.

The agency is seeking help to develop its framework for its risk assessment on “the use of raw manure and other biological soil amendments of animal origin.”

Comments are due by May 3 and can be filed electronically, by mail and via fax. Instructions on how to file comments are included in the comment notice in the Federal Register.


FDA’s Michael Mahovic, center, with Agricultural Research Service (ARS) scientists Patricia Millner, left, and Manan Sharma, examine a manure-treated soil sample taken at ARS’ research facility in Beltsville, MD. Millner and Sharma, both microbiologists, are the principal investigators in an ARS team conducting FDA-funded research into the safe use of manure and compost. (Photo by Peggy Greb, ARS/USDA)

“Before starting the assessment, the agency wants the help of stakeholders in the produce industry, the animal agriculture industry, academia and members of the public in developing the model for this work,” according to the FDA.

“A notice published in the Federal Register requests public comments and scientific data and information, including information about how farms use raw manure and what strategies should be considered to reduce public health risk.”

Some of the concerns about the use of raw manure on fresh produce are addressed by Samir Assar, director of the FDA’s Division of Produce Safety, who posted his answers to frequently asked questions recently. Following are excerpts from three of the FAQs and Assar’s answers:

Question: What are FDA’s concerns about the use of raw manure as fertilizer in crop production?

Answer: This is a food safety issue. Raw manure has the potential to contain foodborne pathogens. Pathogens that live in the intestines of animals can be transmitted from their manure to produce in a number of ways and from there to people under certain conditions. …

A 2015 FDA report on the assessment of the risk to public health from on-farm contamination of produce identifies (biological soil amendments) of animal origin as a potentially significant source of pathogens.

Question: What is the benefit that farmers see in using raw manure as fertilizer?

Answer: There are a number of reasons why growers may use raw manure. They see it as an effective way to provide nitrogen and other nutrients to the soil, and maintain soil quality and health.

There’s a cost factor, too, since it’s readily available at a lower cost. A produce grower, for example, may use manure provided by a neighboring dairy farm. Some small farms may lack the infrastructure to compost properly, leading them to use applications of raw manure. …

When the FDA first proposed the Produce Safety rule mandated by the FDA Food Safety Modernization Act (FSMA) in 2013, the proposed criteria included a nine-month interval between the application of raw manure and other untreated (biological soil amendments of animal origins) and the crop harvest when certain application methods are used. Many growers and other stakeholders in the produce industry objected…

In response, the FDA decided to reserve a decision on the minimum application interval and to conduct additional research and a risk assessment, which can evaluate the impact of interventions that include the use of application intervals. …

Question: In the meantime, what protections do consumers have from raw manure if it’s contaminated?

Answer: We have placed restrictions on how raw manure is applied. The final Produce Safety rule requires that covered farms not apply raw manure in a manner that contacts produce covered by the rule during application. …

To minimize the chance of contamination, we also stated that we believe it would be prudent for farmers to comply with the USDA’s National Organic Program standards related to raw manure use while the research and risk assessment is ongoing. These call for a 120-day interval between the application of raw manure for crops in contact with the soil and 90 days for crops not in contact with the soil.

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