Ever so often, I’m reminded of a Detroit Free Press columnist in the last century - - Sydney Harris - - who offered a comment on “something I discovered while looking for something else,” or something like that. It’s happened to me several times over the years, most recently just now. So many issues, big and not quite so big (there are no small issues in agriculture) invite opinion and commentary. Sifting among a few of the many potential, I ran across the issue, “Food Safety Modernization Act proposed rule for Preventive Controls for Human Food”.
I was instantly reminded that Michigan Farm Bureau, the state’s largest farmer organization is quite concerned about the range and complexity of this series of proposed regulations, and the likely direct impact these changes will have on the food PRODUCERS. MFB’s concern, of course, deals with Michigan producers, but these are Federal regulations, applying to all the places subject to FDA influence and directives.
As is the case most often with the U.S. regulatory procedure, it’s like the mill wheels of justice, which grind exceedingly fine - - and slowly. The revised rules don’t go into effect immediately. The proposed rule was published in January of this year, and any comment you want to make is due by November 15th. My own eyes glazed over long before I could get all the way through the edited version - - No wonder members of Congress occasionally vote on something they don’t fully understand.
I’m reminded of the story, supposedly true, about why so many laws and other regulations are so intricate and wordy. The story goes, that, way back, literacy was not prized, so it fell to lawyers to write the laws. They were paid according to how many words were required to present the message. Old habits die hard, we’re told.
These rules will apply to many domestic and foreign firms that manufacture, process, pack or hold human food. Now, get this: These firms would be required to have written plans that identify hazards, specify what steps will be taken to minimize or prevent those hazards, identify monitoring procedures and record monitoring results and specify what actions will be taken to correct problems that arise. FDA would evaluate the plans and continue to inspect facilities to make sure the plans are being implemented properly.
What the heck is going on here, you might ask. Well, one of the back grounding paragraphs relating to this proposal refers to “High profile” outbreaks of food borne illness over the last decade; striking one in six Americans have brought widespread recognition that we need a food safety system that prevents food safety problems, rather than a system that simply reacts to problems once they happen.
It’s my guess that the big time processors, packers, etc., to keep the Food and Drug Administration off their backs, will be demanding unimaginable requirements of the Producers; the Farmers. No wonder farm organizations are, as they say, “are concerned.”
Karl Guenther is a retired Kalamazoo farm broadcaster and can be reached at email@example.com. He is a member of Michigan Farm Bureau and an emeritus member of the National Association of Farm Broadcasting.