Sarah Taber - Comment

Hello, First, I want to give my appreciation for the small grower exemptions. I'd like to become a large producer someday. However, I acknowledge that it's inappropriate for small operations where consumers have strong contact with the growers to be treated under the same standards as large operations with an extended handling & middleman chain. I appreciate that this is recognized under the proposed rule. Second, I hope that you can add a caveat for aquaponic produce. Aquaponics is the combination of fish culture with hydroponics; vegetables remove waste nitrates from fish effluent, allowing the water to be reused. The environmental benefits are considerable, allowing aquaculture and vegetable production in areas where water is scarce. The food safety record of aquaponics is excellent. It can be much more profitable than aquaculture or hydroponics alone, meaning local production can assume a larger market share of the produce market than if only field and conventional hydroponics were used. However, the proposed rule would effectively outlaw aquaponics except for very small operations. The proposed rule itself states that Salmonella, E. coli, etc are hosted by *warm-blooded* animals. Fish are ectothermic and do not host these pathogens. This is borne out by all available food safety data for aquaponics. However, I am concerned that the proposed rule would unintentionally outlaw aquaponics due to the oversight of not exempting waste from organisms that do not host human pathogens, particularly fish. I am concerned that my operation would not be able to expand to a scale that would be profitable. I am concerned that this law may criminalize my business in spite of the data showing that it is safe. Please add an exemption for aquaponics! See attached file for the most recent study on aquaponic food safety. Sincerely, Sarah Taber, D.P.M. Postdoctoral Research Associate University of Florida Partner Blue Revolution, LLC Gainesville, Florida