Stephen French - Comment

Putting more burden on the small farmer is the wrong way to go. We struggle as it is more meaningless shotgun approach regulation will not fix any problems. The burden of proof of need for this action should be on the FDA in requiring the FDA to produce statistical evidence of the need for this food safety change. Small farmers are typically more particular about food safety than "mega farmers" as they will consume the products also. Has the FDA shown data to, support such a massive change in policy, that show small farmers food handling practices contribute to public health problems at a frequency and sickness per incident that would be equal to or exceed that of big business farms? FDA should be looking for ways to promote small farms not put them out of business.