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Root stock
by arnie ward
on October 30, 2013 at 5:31 AM
i didnt see anything about meat production. US should follow Europe's example, requring meat to be labeled and traceable from field to table. Pure meat, no hormones, grass fed should be labelled and available on a competitive basis and above all, meat packers, marketers, and farmers held strictly liable for failure of deceit in labelling. It works well in Europe and should be adopted here. The people in Europe demand it.
Reply by Shermain Hardesty
on October 30, 2013 at 11:54 AM
by Rory Dorrough
on October 30, 2013 at 6:43 PM
I grow walnuts on 16 acres. Production is down for a variety of reasons so I believe my farm income is below the threshold for this regulation to apply. However, because I trade labor with a friend, I am probably going to have to comply. He shakes my walnuts and in return I hull, sort, and dry his. As I understand the regulation, this agreement between my friend and I puts me in a commercial, for hire processor category. This year I processed about 16 total tons of walnuts. I'll spend more time trying to comply with the regulation than I did harvesting and processing walnuts. (8 days harvesting and processing, 2 days cleaning the equipment.)
Reply by Shermain Hardesty
on November 13, 2013 at 5:25 PM
Rory, in my comments regarding the FSMA Preventive Controls Rule, I am going to state that a walnut huller/dehydrator should not be classified as a “facility”. Hulling/drying is an extension of the harvest process; the walnuts are not cracked. There is no science-based evidence that warrants requiring walnut hullers to comply with HACCP-based Preventive Controls rules if they hull and dry walnuts for other growers.  
Shermain Hardesty
by Jason Meadows
on November 8, 2013 at 12:36 AM
I agree with your comments about the water testing being unreasonable, the soil amendment requirements conflicting with the organic standards, and the excessive cost of compliance. The time between grazing and crop production should also match the organic standard for manure application or 90 or 120 days.
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