FDA Food Safety Modernization Act Registration

[sqkcrk]

I Posted this Thread here because above all this will effect Commercial Beekeepers more than it will anyone else.

How has or will this mandetory registration effect you? What changes to your beekeeping operation will you have to make? If your State doesn't have Honey House Registration and Inspection Requirements what do youy expect to be the ramification of registering w/ the FDA? Obviously if one does not register one is subject to "criminal or civil penalties under the Food, Drug, and Cosmetic Act, as amended by FSMA."

How many of y'all will be registered or updated before the end of 2012?

[wildbranch2007]

where is honey listed in the act? i searched on it and no hits? I remeber you posting b/4 about getting a notification, is that how you found out about it. I checked my local bee club and the nyhoney produceres and no information that I can see. Penn. has honey house registration, I'll bee seeing a beek from there tomorrow and see if he has heard anything.
I was registered years ago but they never sent me any correspondence.

[sqkcrk]

An e-mail from ABF. Honey is a food. That's how it fits, I guess. ABF recommends registering and then applying for an exemption. Being less expensive than the criminal and civil fines.

[jkola404]

Our state already requires that if you are over certain size that you need to have your honey house inspected and registered. They don't inspect every year but have to pay the $70 dollar fee yearly.

[Ian]

Canada has a voluntary plan in action, and I do not see it being to much longer before it become mandatory also.

[BMAC]

Being that states have to abide by federal law I will wait and see how our ag and markets handle this being they have specific honey statutes.

[sqkcrk]

Who does? NYS? What honey statutes are those?

This will be a topic of discussion during the Fall Mtng of the Empire State Honey Producers Association Meeting.

[BMAC]

I expect it to be part of the fall meeting. Actually looking forward to hearing about it more. I believe the statute states something along the lines that honey and maple syrup operations are not subjected food processing licensing and thus inspection. Less of course we alter or as they put it adulterate the honey. So now I have to state I am not an expert with laws, I do not propose to be a lawyer. Just a hick in the sticks keeping bees and our wicked government off my back.

Though I often wonder why Maple Syrup production is in the same category being syrup producers alter the sap to turn it to sugar and sap can go bad very quickly if not properly handled.

[sqkcrk]

We don't have mandetory Honey House Registration in NYS, but we are subject to inspection. I know folks whyo have been inspected in the past. It became obvious that there were bigger fish to fry and they just became impractical.

Honey and Maple Syrup carry few or no pathogens which can cause harm, so they have been exempt from food processing licensing and inspection, unless something is added to the honey. Such as flavorings in creamed honey.

Many other foods carry more danger if not handled properly, such as milk.

What I will predict is that no one at the eshpa fall mtng will know enough to say what is required ort how to go about doing what is required and what is minimally required. It woulkd be nice if we had an FDA or NYS Ag&Mkts expert on hand, but I doubt we will.

Be sure to say hi when you see me.

[AmericasBeekeeper]

We have state regulation in Florida, but the honey houses are reporting that DHS is walking in and being more critical than the state inspections. I'd hate to go to Gitmo for cob webs around the lights.

[sqkcrk]

Are people having to stop their operations and make changes? Has anyone been closed down?

[AmericasBeekeeper]

No closures I know of yet. Beekeepers in Georgia and Florida are a tight group. They might just get the heads up when inspectors leave one place going to the next. From what I hear, the inspectors are still learning, developing a sense of what is normal and what is a threat. As soon as they hit that first confrontational beekeeper/packer all bets are off. They will come down on you like cops after a high speed chase.

[jim lyon]

Haven't heard of any repercussions up this way. You learn when running a business to expect the worst from what begins as well intentioned initiatives such as this. The devil is always in the details. Your greatest fear is being at the mercy of an over zealous federal employee short on real life experiences but fresh from an FDA training seminar. I have recently seen it with the DOT (where nothing I do has changed except the time it takes to write out about $500 a year in checks) and I am expecting to eventually see it with the FDA. If I get an inspection notice my first call will be to my congressman to find out how I am supposed to comply with regulations that I have never seen.

[Ian]

I do believe in cleanliness and hygienic operating practices when harvesting our crop but I also point out to anyone and everyone that beekeeping is primary food production and we have to be able to work within practical guidelines for production. We produce a raw product, just as the farmer who produces grain for sale, or cattle, or eggs, or milk. Best operating practices have to be implemented, and by doing so we can help prevent source infection of food born illness but there are limits. It all has to be practical and affordable.

Here, if you package honey for sale, or package any other product for sale you have to have a registered facility and they are very strict on the standards in these facilities.
Our beekeeping industry has adapted a voluntary honey house registration plan. And this is to help give producers time to up grade and such. This is beneficial because it allows older producers to make retirement plans which will be phased out in short time, and allows younger producers to plan their capital spending with honey house registration in mind. Most all producers here are in favor of this initiative.

[jim lyon]

I do believe in cleanliness and hygienic operating practices when harvesting our crop but I also point out to anyone and everyone that beekeeping is primary food production and we have to be able to work within practical guidelines for production. We produce a raw product, just as the farmer who produces grain for sale, or cattle, or eggs, or milk. Best operating practices have to be implemented, and by doing so we can help prevent source infection of food born illness but there are limits. It all has to be practical and affordable.

Here, if you package honey for sale, or package any other product for sale you have to have a registered facility and they are very strict on the standards in these facilities.
Our beekeeping industry has adapted a voluntary honey house registration plan. And this is to help give producers time to up grade and such. This is beneficial because it allows older producers to make retirement plans which will be phased out in short time, and allows younger producers to plan their capital spending with honey house registration in mind. Most all producers here are in favor of this initiative.

I would agree with that approach. We as beekeepers, though, need to know what needs to be done and what the timetable is and some degree of reason needs to be used. Is it really time well spent for FDA inspectors to be throwing their weight around at this point in time when there is no reason to think that anyone is getting sick from the product that we produce. Seems to me that the greatest threat to honey purity are off label concoctions that can taint the honey rather than problems with honey house cleanliness. Perhaps the FDA needs to spend more time looking at the end product than the process.

[Ian]

I absolutely agree.
AND tell me this,
If our honey does have to be processed in a registered facility, which would make our honey production documented right from the hive to the barrel,
then why would our honey still be priced against the un documented honey coming in from off shores. And by that I mean China. And if there are documents provided, does the government believe the documents behind that stuff????

[Ian]

A producer from around here went to Chili on a beekeeping business exploratory something or another.
On the record, the producers were very favorable and respectful of our strict Canadian food standards and guidelines.
Off the record, in the pub, the producers were laughing at our food standards and guidelines. They could not believe the extra costs the government placed on producers for tractability and registrations for facilities. To make a long story short, they told him that what happens in Chili and most every other country in the world is they give bribes. They actually budget in brides as one of their year business expenses to pass inspection and satisfy government requests.
And our honey is sold against this stuff? If food safty and food standards are that important to processors AND consumers then why are they even looking at this other stuff?

[BMAC]

I see this registration being nothing more than an additional tax on the backs of those who are working hard for a living. It should not be up to the feds to enforce inspections and registrations on food. That is a local government function from towns/citys to state. Has honey ever caused a food borne illness?
Does honey promote food borne illness?

Though I understand this act isnt directed at honey, it will possibly affect us as beekeepers. Maybe the ABF should lobby the retarded law makers to help make sense of it all and keep us out.

[Ian]

how are you going to argue that to a bunch of bureaucratic who have never seen outside of an office building ? To them honey is food just as everything else

[sqkcrk]

Though I understand this act isnt directed at honey, it will possibly affect us as beekeepers. Maybe the ABF should lobby the retarded law makers to help make sense of it all and keep us out.

Which is sited in the ABF announcement. That an under $500,000.00 exemption was sought by a Senator. I didn't get whether it was granted. ABF recommends complying w/ the Act and applying for an exemption. What a bother.