There's a comment period open right now on how small-volume producers are treated under the federal food safety modernization framework, and it's the kind of rulemaking that's easy to miss because the headline reads like paperwork. It isn't. The exemption thresholds under discussion determine whether a farmstead making a few hundred wheels a year carries the same preventive-controls burden as an operation running three shifts, and our Food Safety Committee has been tracking the docket since it opened.
We've filed comments on this kind of exemption question before, and the pattern is consistent: the agency drafting the rule hears overwhelmingly from large processors with compliance departments built for exactly this work, and much less from the farmstead and micro-creamery members who'd actually have to absorb a lower threshold. That imbalance in who shows up to comment shapes the final rule more than most members realize, and it's a large part of why we ask members to weigh in every time a window like this opens.
Why the threshold number matters
The framework generally exempts the smallest producers from certain preventive-controls paperwork based on annual sales volume, with the exemption narrowing as revenue grows. Those dollar thresholds are inflation-adjusted and republished each year, typically in March, which is part of why the timing of this comment window matters: whatever line gets set now carries into the figures that take effect for the coming season. Where exactly that line sits determines whether a two-person creamery selling primarily at farmers' markets needs a full written food-safety plan on file or a lighter-touch version scaled to its size. Move the threshold down and a farmstead that's been selling the same volume for a decade can suddenly find itself reclassified, with a compliance cost that didn't exist the season before.
Our position, consistent with past filings, is that exemption thresholds should track actual production volume and direct-sale patterns, not a single number written with a national supply chain in mind. A twelve-cow operation selling at three farmers' markets faces a fundamentally different risk profile than a regional wholesaler, and a compliance requirement that doesn't distinguish between them tends to push the smallest, often most food-safety-conscious makers out of business rather than making anyone safer.
What we're asking members to do
If you want your name on the record, our advocacy page has a short letter template you can adapt in five minutes — we'd rather you rewrite it in your own words with your own numbers than sign it as-is, because specific, member-written comments carry more weight than form letters. Comment periods like this one typically stay open for thirty to sixty days, so don't wait until the last week.
One of our longtime members, a Midwest farmstead owner who's filed more of these letters than almost anyone in the federation, put it to us this way at a recent committee call: "Nobody drafting this rule has ever had to explain a compliance cost to a bank loan officer. We have to be the ones who explain it to them." That's the register we'd like every comment to hit — specific, grounded in your own books, not a form letter with your name pasted on top.
If you're newer to this kind of advocacy and aren't sure where to start, reach out to our Membership & Outreach Committee — they can connect you with a member in a similar-sized operation who's been through a comment cycle before and can walk you through what made their letter land.
The International Cheese Federation (ICF) and More Cheese are entirely fictional. This post is demonstration content created for MemberJunction. All people, organizations, events, courses, certifications, figures, and quotations in it are invented, and nothing here represents a real association, a real business, a real person, or real professional advice.