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  1. #21
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    Default Re: FDA Food Safety Modernization Act Registration

    Quote Originally Posted by Ian View Post
    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
    But they have the ticket book. So, what are you going to do when someone says "Hey, this window w/ one pane of glass which is stationery only has one screen. It has to have two." Supposedly actually happened.

    They do have the ticket book and the means of backing up the issuing of them.
    Last edited by sqkcrk; 10-18-2012 at 08:06 AM.
    Mark Berninghausen "That which works, persists."

  2. #22
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    Default Re: FDA Food Safety Modernization Act Registration

    Mark speaking of apiary inspectors, have you had one out to your yards yet?
    Last edited by JohnK and Sheri; 10-18-2012 at 07:35 AM. Reason: off topic

  3. #23
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    Default Re: FDA Food Safety Modernization Act Registration

    Apparently I did have a visit from an Inspector. Other than the initial visit, early in the Summer, I wasn't aware that any further inspection had taken place until I got my Health Certificate/Interstate Transport Papers.
    Mark Berninghausen "That which works, persists."

  4. #24
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    Default Re: FDA Food Safety Modernization Act Registration

    Interesting. I have not seen nor heard from him yet. I will have to call Paul early next week after I finish pulling the rest of my honey.

  5. #25
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    Default Re: FDA Food Safety Modernization Act Registration

    I copied some interesting points for some of questions and answers fo the new act, the first says its delayed.
    FDA delays Food Safety Modernization Act Registration Process



    On September 28, the Food and Drug Administration announced that due to the complex clearance and implementation process they were unequipped to implement the food facility biennial registration procedure mandated by the Food Safety Modernization Act (FSMA) that was set to begin on October 1, 2012, This delay effects food manufacturers and food wholesalers that process and package food, not retailers. The FDA has not given any timeline as to when the system would go live online and has yet to give a decision on whether or not the registration deadline under FSMA will be extended past December 31. When registration renewal does become available, the FDA will issue new guidance which will supersede the existing guidance and will address the renewal requirement which againhttp://www.cficweb.org/wp-admin/edit.php will only affect food wholesalers, not retailers. When any new information becomes available, NGA will update the membership. << now its says exluding retailers in the bill I found where I thought it also said if you only retail you do
    << not have to be inspected but I couldn't find it to copy

    IC.3.8 Is there a fee for registration, updating a registration, or renewal of registration?
    No. There is no fee associated with initial registration, updating a registration, or renewing a registration.


    IC.1.1 FSMA has several provisions on inspections and compliance. What will be new?
    For the first time, FDA has been given an inspection mandate. The legislation requires inspections to be based on risk, and the frequency of inspections to increase. It calls for all high-risk domestic food facilities to be inspected within five years of the bill’s signing and then at least once every three years after that. Further, all other domestic food facilities are to be inspected within seven years of the bill’s signing and then at least once every five years thereafter.


    F.1.1 Is there a registration fee required under FSMA?
    FSMA does not require a registration fee to be paid by registered facilities.


    F.1.2 Will there be a fee associated with FDA inspections?
    There is no fee for an initial FDA inspection. FSMA authorizes FDA to assess and collect fees related to certain domestic food facility, foreign food facility, and importer reinspections. The fee for reinspection is to cover reinspection-related costs when an initial inspection has identified certain food safety problems.
    >> no fee for inspection but a fee for reinspection.

    F.2.12 Will States conduct FSMA-related reinspections?
    Generally, FDA intends to conduct all reinspections that could result in the assessment of fees under FSMA, even in the case where an initial inspection was conducted under state contract.

    << so if a state does the inpection and you have issues, the feds will reinspect you and charge you the $241 dollars an hour plus travel and hotels. So it would be my guess in N.Y. << where the don't now inspect, the the feds would do it.



    F.2.13 How long does the responsible party have to pay the fees?
    Payment must be made within 90 days of the invoice date.



    F.2.14 What happens if the responsible party or U.S. Agent does not pay?
    Any fee that is not paid within 30 days after it is due shall be treated as a claim of the United States government subject to provisions of subchapter II of Chapter 37 of Title 31, United States Code.


    G.5 Does FDA have sufficient funding to implement the new rule?
    The funding we have available through the annual budget cycle and fees impacts the number of FTEs we have and will be a factor in the way that FDA handles its significant and far-ranging activities, including the way that this legislation is implemented. For example, the inspection schedule in the legislation would increase the burden on FDA’s inspection functions. Without additional funding, FDA will be challenged in implementing the legislation fully without compromising other key functions. We look forward to working with Congress and our partners to ensure that FDA is funded sufficiently to achieve our food safety and food defense goals



    <<now g5 is the one I would get everyone includeing the bee clubs, individuals, national organizations to key on, get some of the indivuduals from tailgater to write up a nice form <<letter to our congresspeople and senaters and make sure it doesn't get funded. won't help but at least would give us something to do over the winter that would be constuctive.

    I like rainy days some times.
    mike syracuse ny
    I went to bed mean, and woke up meaner. Marshal Dillon

  6. #26
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    Default Re: FDA Food Safety Modernization Act Registration

    this is a lawyers interpretation of the part of the law that I couldn't copy about retail being excempt from inspection.


    A. Covered Facilities (this is a lawyers interpretation of the actual law.)



    The FSMA requires FDA to amend the definition of "retail food establishment"

    5 to clarify that the sale of food directly to consumers includes the sale of food at a roadside stand or

    farmers’ market, sale and distribution of food through a community supported agriculture program,

    6and sale and distribution of food through any other direct sales platform as determined by FDA. FSMA, § 102(c). FDA regulations currently exempt retail food establishments from the food facility registration requirement. 21 C.F.R. § 1.226(c). This amendment will clarify that, for purposes of determining whether a facility is a "retail food establishment," direct sales to consumers include sales at a farmers’ market, roadside stand, or other direct sales platform.



    gave up trying to copy the part of the law due to copy issues, but this may meen if you only retail you don't have to register
    mike syracuse ny
    I went to bed mean, and woke up meaner. Marshal Dillon

  7. #27
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    Default Re: FDA Food Safety Modernization Act Registration

    But not direct store delivery of a food item never otherwise out of my hands? I sell almost all of the honey I produce directly to those who sell it to the end consumer.
    Mark Berninghausen "That which works, persists."

  8. #28
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    Default Re: FDA Food Safety Modernization Act Registration

    well I'm modifying my buisness plan, I will extract only enough honey to sell retail, the rest I will load up the honey supers and deliver to the people that buy wholesale from me, and they can extact it and retail it like they do now, I had allready bought a trailer to haul the supers anyway. only thing I have to look up is if (I think its called phosmet(sp) gas that some beeks use to kill the extra bees will also kill SHB. I would only lose one large purchaser of my honey as they don't have a large extracting room. the price of they honey will have to rise for the added trips to there honey houses I would think. I'm also looking into the excemptions they talk about.
    mike syracuse ny
    I went to bed mean, and woke up meaner. Marshal Dillon

  9. #29
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    Default Re: FDA Food Safety Modernization Act Registration

    I wouldn't get too excited about it yet. It looks like everyone who sells honey will have to register. (I think i already did a few years ago) but there are supposed to be exemptions from the worst of the paperwork requirements under the Testor amendment. But it seems the rules are still being written... so it will be prudent to keep up with it.

    Does anyone really believe China will obey these rules? I am sure they will have all the paperwork required.

  10. #30
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    Default Re: FDA Food Safety Modernization Act Registration

    "The Tester-Hagan Amendment, sponsored by Democratic Sens. Jon Tester of Montana and Kay Hagan of North Carolina, defines small farms as those that average annual gross revenue of less than $500,000 over three years and that sell a majority of their products directly to consumers, restaurants or grocery stores within the same state as the farm or within 275 miles of it. Farms that meet this definition will be exempt from developing a detailed food safety plan, keeping extensive records, and complying with produce safety rules the FDA will finalize over the next two years."http://www.foodsafetynews.com/2011/11/powerful-coalition-gains-exemption-for-small-farmers/

  11. #31
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    Default Re: FDA Food Safety Modernization Act Registration

    I've looked can anyone find where the amendment acutally passed? I've also read that it doesn't excempt you from being inspected even though they still haven't written the requirements that I can find any way. And the fda still gets to write up after the acutal bill was passed the requirements? I agree with loggermike better to keep up with it, but most of the information I find is dated 2010, thats 2 years old, whats happened in the last two years?
    mike syracuse ny
    I went to bed mean, and woke up meaner. Marshal Dillon

  12. #32
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    Default Re: FDA Food Safety Modernization Act Registration

    Will keep looking for more recent news on this. I think you are right, the inspection part will apply to everyone. And you were also right, they intend to charge $221 per hour for any follow up inspections. I call that greedy.

    Just found this: The Federal Food Safety Modernization Act: Impacts in Import and
    Small-Scale Production Sectors

    http://dash.harvard.edu/bitstream/ha...pdf?sequence=1

    "Despite the opposition, the Senate bill passed with a modified version of the Tester

    Amendment.56 Members of the House did not have the opportunity to make changes to the bill

    before it was signed into law, but they did express their reservations regarding the Tester

    Amendment. Representative Pitts voiced a common concern, stating “[w]hile we do not want to

    overly burden small facilities and small farms, we’ve learned in our committee hearings that

    food-borne pathogens don’t care if you’re a big facility or a small facility, a big farm or a small

    farm. They affect everyone.”57 Others noted that the Tester amendment may require the

    government to “exempt similarly sized companies in developing countries from our standards.”
    Last edited by loggermike; 10-21-2012 at 07:41 AM. Reason: additional info

  13. #33
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    Default Re: FDA Food Safety Modernization Act Registration

    a post from bee-l from a person who had read the honey packers part of the bill






    http://community.lsoft.com/scripts/w...&F=&S=&P=47234







    I looked over the new homeland security food
    regulations for honey packers. You can't even keep a broom or mop with a
    wood handle in the place. Clorox under lock and key.
    mike syracuse ny
    I went to bed mean, and woke up meaner. Marshal Dillon

  14. #34
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    Default Re: FDA Food Safety Modernization Act Registration

    Pretty interesting article Bob wrote. It was dedicated more to CCD with just a little blurb about the homeland security trash. A fairly interesting political spin on it as well.

  15. #35
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    Default Re: FDA Food Safety Modernization Act Registration

    So did anyone figure anything out after listening to the FDA lady about FSMA on Saturday?

  16. #36
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    Default Re: FDA Food Safety Modernization Act Registration

    Unfortunately I did not get to hear her whole talk nor get to participate in the question and answer part. I heard she declined to say who would be exempt from Inspection. I can send you the link to the literature which she passed out. But I don't know if it will do you much good. Unless you are going to register.
    Mark Berninghausen "That which works, persists."

  17. #37
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    Default Re: FDA Food Safety Modernization Act Registration

    I did a brief search on FSMA exemptions and they are NOT clearly defined as exemptions. Less I am looking in the wrong spot. It seems like a huge headache for some of the things they would require for inspection worthy operations. Then the fear of having Dept of Homeland Security come and watch just to write citations is a nauseating thought.

    Did you look in the back of the blue book that lady handed out for what they look at during inspections?

    Some of it has to do with searching vehicles on the property. Does that mean I have to search my own vehicles on the property in case I might be a terrorist?

    I think the whole FSMA concept was poorly put together.

  18. #38
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    Default Re: FDA Food Safety Modernization Act Registration

    Quote Originally Posted by sqkcrk View Post
    Unfortunately I did not get to hear her whole talk nor get to participate in the question and answer part. I heard she declined to say who would be exempt from Inspection. I can send you the link to the literature which she passed out. But I don't know if it will do you much good. Unless you are going to register.
    could you post the link so we could all see it? thanks
    mike syracuse ny
    I went to bed mean, and woke up meaner. Marshal Dillon

  19. #39
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    Default Re: FDA Food Safety Modernization Act Registration

    Will do, this evening. Gotta go do some work. Later guys.
    Mark Berninghausen "That which works, persists."

  20. #40
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    Default Re: FDA Food Safety Modernization Act Registration

    I couldn't let this rest. I called up FDA in Maryland. They told me on the phone exemptions: Home based operations, tax code 50133 (not for profit).

    So I asked for where to find our exemptions on the internet and she gave me
    http://access.fda.gov

    Click on the more information under food facility registration which brought me to the following:
    http://www.fda.gov/Food/FoodDefense/...81637.htm#IIId


    Which within clearly states FARMS are exempt.

    Sounds like I am legally NOT required to register.

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