Andrew and Sons, LLC - Comment

Small farmers are not in the position to develop and implement an extensive food safety program due to monetary and employee resources. The FDA should take in account when issuing new rules that the audit process needs to become streamlined and all auditing standards be comparable across all certification bodies. The end audit result is the same but the process varies widely and can cause unnecessary duplication and expense. Small suppliers are a critical ink in the food chain. As the FSMA rules are developed, it is imperative to consider the costs and complexities of compliance for each component in the system. Keeping the costs associated with certification as reasonable as possible ensures that growers, shippers, distributors, and retailers can be required to meet the standards and ensure a safe supply of fresh produce. Audit costs continue to rise and our facilities can pay from $1500 to $4000 for each annual audit.