Anonymous - Comment

The Idaho-Oregon Fruit and Vegetable Association (IOFVASN)represents onion and fruit growers in Idaho and Eastern Oregon. Idaho and Eastern Oregon is home to one of the largest onion growing regions in the United States. We join with the over 270 groups and are requesting that the proposed rules comment period be extended an additional 120 days (May 16, 2013 - September 13, 2013). FSMA/FDA's new rules will have a huge impact on the growers and shippers in Idaho and Eastern Oregon as well as the U.S. fresh produce industry. FDA took two full years to write the "proposed rules". An extended comment period for affected agricultural interests and businesses is more than justified. Since produce growers, shippers, marketers, and processors are being asked to substantiate specific positions relative to the proposed rules, with accompanying scientific evidence, it is impossible to evaluate the extent of studies needed, compose and write such studies to undergird positions different from FDA's proposal. Time is needed to commission appropriate studies, build study processes, locate qualified professionals to conduct research, and to generate funding from private sources for research. It will be necessary to generate funding for public research, and finally the studies will need to be conducted which will easily take two, three, or more years. The federal government is pressing the adoption of new laws and regulations that will create many changes in food production and distribution, and will add untold expense to the growers in Idaho and Eastern Oregon as well as across the United States. It is imperative to get this right. It is only fair to allow significant extension of time to comment on the initial proposed rules.