FDA seeks input on risk assessment regarding use of raw manure as produce fertilizer.

  • Among the issues addressed in FDA’s final rule related to produce safety under the FDA Food Safety Modernization Act (FSMA) is the use of untreated biological soil amendments of animal origin (BSAAO).  Untreated BSAAO are essentially raw manure from cattle and other farm animals (e.g., poultry litter, horse manure).  Some produce farms use untreated BSAAO for a variety of reasons, including the fact that they are relatively cheap, readily available, and serve as rich nutrient sources for growing crops.
  • FDA is planning to conduct a risk assessment to determine the extent to which the use of raw manure as fertilizer in growing crops poses a risk to human health and to develop an approach to help prevent contamination that leads to foodborne illness.  To kickstart this process, the Agency is seeking input from stakeholders in the produce industry, the animal agriculture industry, academia, and members of the public.  FDA is specifically interested in receiving scientific data on pathogen detection and quantification, the prevalence and use of untreated BSAAO, and on-farm practices with respect to BSAAO.
  • In FDA’s view, the use of untreated BSAAO is a food safety issue.  Pathogens that live in animal intestines (e.g., E. coli O157:H7 and Salmonella) can be transmitted to manure and then to produce when untreated BSAAO are applied during cultivation.  The final produce safety rule does not prohibit the use of untreated BSAAO on farms, and in fact, FDA has reserved a decision on the minimum interval between the application of untreated BSAAO and the crop harvest when certain application methods are used.  FDA anticipates developing a quantitative application interval standard in the future, and the information derived from this risk assessment likely will play an integral role in standard development.  A Q&A about FDA’s current request for comments is available here, and comments may be submitted until May 3, 2016.