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IAPO Leadership Council



October 31, 2013
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Take Action To Ensure Access to Healthy, Affordable Fruits and Vegetables! 


The Food and Drug Administration (FDA) has released proposed rules on four aspects of the Food Safety Modernization Act (FSMA). While the law and proposed rules are complex, the Local Foods Workgroup of IAPO is concerned that two of the rules (the produce rule and preventive controls rule), as currently proposed, would reduce the accessibility and affordability of healthy fruits and vegetables in the U.S., which could have major implications for obesity prevention efforts. We urge you to learn more about FSMA and submit comments to the FDA. The deadline for submitting comments on those two rules is November 15, 2013.

Suggested talking points for your comments, developed by Becca Klein, the Agricultural Policy Project Director at the Johns Hopkins Center for a Livable Future, and the Fair Food Network, include:
  • Implementation of the Food Safety Modernization Act must serve to protect public health by supporting systems that reduce acute foodborne illness risk and allow for the development of healthy food systems that lead to reduced diet-related chronic disease risk.
  • The FSMA statute includes provisions that recognize the need to have balanced, commonsense regulation that protects the economic viability of responsible, well-run American farms while also providing the best health protection possible to consumers. There are several ways in which the proposed regulations (both the "Produce Rule" and the "Preventive Controls Rule") differ from the statute that could have a net negative impact on health and nutrition.
  • Biological diversity adds to soil health, protects our environment and healthy soils can boost the nutrient content of food. Unfortunately the proposed rules do not align with National Organics Program standards and would result in stripping away conservation measures that have been in place for years to protect soil, air, and water quality without actually increasing the safety of the food produced. 
  • Some farms add value to their products by processing them on-farm or participate in smaller-scale processing facilities. These farmers and facilities are subject to local food safety laws that provide reasonable regulation that accurately reflects the actual risk of the food they handle. However, the FSMA proposed rules do not provide clear and coherent distinctions between what is a farm and what is a facility and create a web of redundant and confusing regulatory oversight and compliance that will not increase consumer food safety and will cause many small businesses to close.
  • Successful farm to school programs across the country rely on on-farm and facility-based minimal processing of fresh agricultural products in order to incorporate the healthy items into food service programs. As written, the proposed rules do not reflect a clear understanding of this small-scale processing model and would hinder successfully providing farm-fresh food to schools.
  • CSAs (Community Supported Agriculture) are creatively finding ways to provide healthy food to low-income consumers, often by aggregating the products of several local farms. Under the proposed rules this aggregation centered CSA model would no longer be considered direct marketing by farms, but rather highly regulated facilities.
  • The agriculture and health communities can work together to agree upon science-based, practical, and implementable rules that will genuinely improve the safety of food and improve access to healthy American- grown food for Americans.
Submitting Comments: You can submit your comments in TWO places - to the Produce Rule ( and to the Preventive Controls Rule (

Background: The Food Safety Modernization Act (FSMA) is the first major update of federal food safety laws since 1938. FSMA gives the FDA broad new powers to prevent food safety problems, detect and respond to food safety issues, and improve the safety of imported foods. FSMA does not change food safety regulations for meat, poultry, and egg products, which are under the U.S. Department of Agriculture's jurisdiction.

FSMA authorizes new regulations at the farm level for producers and certain facilities. Specifically, FSMA mandates the establishment of:
  • Standards for produce production (Produce Rule, comments due Nov. 15th)
  • Food safety measures for facilities that process food for human consumption (Preventive Controls Rule, comments due Nov. 15th)
  • Foreign Supplier Verification Programs (FSVP) for Importers of Food for Humans and Animals Proposed Rule (comments due Nov. 26th)
  • Accreditation of Third-Party Auditors/Certification Bodies to Conduct Food Safety Audits and to Issue Certifications Proposed Rule (comments due Nov. 26th)
Resources that might be helpful as you write your comments include the following:
The Local Food Systems IAPO workgroup thanks you for taking action! 


About IAPO

The Illinois Alliance to Prevent Obesity (IAPO) is a statewide coalition comprised of stakeholders working for a state-level response to the obesity epidemic. IAPO works to shape and advance solutions to reverse dangerous obesity trends.

IAPO supporters believe that Illinois must respond to the obesity epidemic by developing coordinated systems, policy improvements and investment on the scale of the problem.  This initiative was launched and is coordinated by the Illinois Public Health Institute (IPHI).  To learn more about IAPO, visit . 

Illinois Alliance to Prevent Obesity

Convened by the Illinois Public Health Institute   

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