Earlier this year, the federal food-safety regulator finalized a narrow exemption to its additional traceability recordkeeping rule, carving out a specific category of Grade A cottage cheese from the toughest requirements. It was a small change on paper, but it was also proof that the exemption boundaries in that rule aren't fixed — they move when someone brings the regulator a clear, well-documented case for why a given product or process doesn't need the same tracking burden as everything else. Our Food Safety Committee has been watching that door stay open, and this month we're asking members to help us push through it again.
The rule in question requires detailed lot-level tracking for a long list of foods, with recordkeeping obligations that scale up sharply for anyone above certain volume thresholds. Most of our larger members have already built the systems to comply. The members we hear from every week are the ones just below that line — small farmstead and artisan operations where the paperwork burden isn't proportional to the actual food-safety risk, because a five-person creamery selling direct to twelve retail accounts doesn't have the same traceability problem as a plant shipping pallets across six states.
What the federation is asking for
We're compiling a member comment package for the next open comment window, and it needs your numbers, not just your opinion. Specifically: how many hours per month your current recordkeeping actually takes, what it would cost you to hit the fuller requirement if you crossed the volume threshold, and whether you've had a traceability-related recall or near-miss in the last three years. That last number matters more than any of us would like — a regulator weighing an exemption wants evidence that light-touch recordkeeping hasn't produced light-touch safety outcomes, and right now the strongest argument for small-producer exemptions is a clean track record, not a philosophical case about proportionality.
If you sell interstate at all, even occasionally, your comment carries more weight than one from a strictly local seller, because interstate shipment is where the rule's underlying food-safety concern is sharpest. One of our longtime advocacy volunteers has personally logged well over thirty legislative and rulemaking actions on exactly this kind of issue, and his standing advice to first-time commenters is blunt: don't write a paragraph about principle, write three sentences with a number in each one. Regulators read a lot of comments. The ones with specific, verifiable figures are the ones that get cited when the final rule is drafted.
Where this fits with what's already changed
This isn't the first time we've asked for this kind of comment, and it won't be the last — the exemption boundary gets revisited on its own schedule, not ours, and every round is a fresh chance to move it a little further in the direction that makes sense for small producers. Members who submitted numbers in a prior round should still send updated figures; a comment based on last year's volume doesn't carry the same weight as one reflecting where your operation stands today.
If you want to contribute a comment but aren't sure how to frame your numbers, contact the Food Safety Committee before you write anything — a fifteen-minute conversation up front saves most members from submitting a comment that's accurate but not useful. The window doesn't stay open long, and we'd rather help you get it right the first time.
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.