from the New England Farmers Union

New England Farmers Union and the National Sustainable Agriculture Coalition (NSAC) are conducting a survey of farmers to better understand how they use untreated or raw manure on their farms. The US Food and Drug Administration (FDA) is currently asking for information regarding on-farm use of manure, as well as existing scientific research on the subject.

The deadline to complete the survey is May 20. The information you submit will remain anonymous unless you choose to identify yourself. The responses will be aggregated and used by New England Farmers Union and NSAC in their comments and ongoing dialogue with FDA to ensure FDA’s new food safety standards work for sustainable agriculture.

If you are a farmer, please fill out the survey.

If you work with farmers, please share this survey with them.

Background The fact that FDA is even asking for this information is the result of a huge victory the sustainable agriculture community achieved during the Food Safety Modernization Act (FSMA) proposed Produce Rule comment period. FDA had proposed rules that would have severely restricted the ways in which farmers use manure — particularly regarding the length of time between the last application of raw or untreated manure to a field and when a produce crop is harvested from that field. Farmer comments \ demonstrated to FDA that their proposed approach (a nine month waiting period) did not adequately account for regional variations in climate and growing seasons or the diversity of production practices that farmers use across the country. As a result, FDA agreed to go back to the drawing board. This request for information by FDA is the first step in that process. 

FDA has committed to doing a full risk assessment that will look at pathogen survival while considering different agricultural and ecological conditions (e.g., soil types, application methods, geographic locations, climatic factors) and considering different time intervals between when manure is applied and the crop harvested. The risk assessment will eventually inform FDA’s next proposed standard setting a required minimum application interval for raw or untreated manure. To make sure this risk assessment, and the final standard, fully accounts for the diversity of ways in which farmers use biological soil amendments, particularly raw or untreated animal manure, we are asking for your participation in the survey below.

You can find out more information on FDA’s risk assessment process on NSAC’s website.

Photo credit: USDA