Tom P. Honigford - Comment

Document ID: FDA-2011-N-0921-0039
Document Type: Public Submission
Agency: Food And Drug Administration
Received Date: February 22 2013, at 12:00 AM Eastern Standard Time
Date Posted: March 13 2013, at 12:00 AM Eastern Standard Time
Comment Start Date: January 31 2013, at 12:00 AM Eastern Standard Time
Comment Due Date: May 16 2013, at 11:59 PM Eastern Standard Time
Tracking Number: 1jx-83tu-a6uu
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This is comment on Proposed Rule

Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption: Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventive Controls for Human Food; Public Meeting

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As a farmer, I largely agree with the proposed standards. I feel the 270 day waiting period to apply manure is unreasonable. Not only does this put an undo burden on many growers that have supplies of manure (fertilizer they can't use), but it will also cause some growers to over apply, to make up for leaching, 270 days in advance of a crop to meet the standards. This will cause water quality issues and other environmental problems