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View Full Version : No excpetions on registration currently on Dollar of units sold.



delivron
01-17-2013, 01:15 AM
There are is no known exception base on size. They have more to do how you sell your product.

There is a current comment period about what constitutes a small business and how inspections will be conducted.
But the rules are not currently enforce.Effective and Compliance Dates and Definitions for Small and Very Small Businesses


FDA is proposing the following effective and compliance dates for businesses subject to the proposed rule. Recognizing that small and very small businesses may need more time to comply with the requirements, the compliance dates are adjusted accordingly.
• Effective Date: 60 days after the final rule is published
• Compliance Dates:
o Small Businesses—a business that employs fewer than 500 persons and that does not qualify for an exemption would have to comply two years after publication of the final rule.
o Very Small Businesses—Three options are being proposed for the definition of a very small business:less than $250,000, less than $500,000, and less than $1,000,000 in total annual sales of food, adjusted for inflation. Very small businesses, which would be considered “qualified facilities” and subject to modified requirements for preventive controls, would have to comply three years after publication of the final rule.
o Other Businesses—a business that is not small or very small and does not qualify for an exemption would have to comply one year after publication of the final rule.
Economic Impact of the Proposed Rule
The proposed rule is aimed at reducing the public health burden of foodborne illness. FDA estimates that close to 1,000,000 illnesses each year are attributable to food that would fall under the scope of this proposed rule. The economic cost of illnesses avoided is $2 billion a year. The proposed rule has a first-year cost to industry of $701 million and an annualized cost of $472 million using a 7 percent discount rate according to Office of Management and Budget guidelines. The proposed rule would cover an estimated 97,600 domestic and 109,200 foreign facilities

More information at: http://www.fda.gov/Food/FoodSafety/FSMA/ucm334115.htm

spencer11
01-17-2013, 06:59 AM
So I make less then 250,000 a year in general and don't make that off syrup, so do I need to register by the end of the month?

mapleack
01-17-2013, 07:59 AM
My take is that there is an office full of bureacrats that needed to justify their existence so they wrote all this BS. All they needed to do was say "if you produce, manufacture or grow a food product and sell it, you have to register." No confusing page after page of BS, just straightforward done. I detest big gov't.

nymapleguy607
01-17-2013, 08:31 AM
I e-mailed the Field advisor for our county farm bureau, this is what he found out for me,

I still have to read thru the nearly1300 pages that came out before I headed to Nashville, so in general, this is what I know. As long as they sell less than $500,000/yr AND at least half of that direct or to restaurants/retailers AND are just doing sap/syrup, they are exempt as low-risk. IF, however, they sell mostly to a wholesaler or bottler, or do maple candy/mustard/other value-added products, they probably will be under the new regs. If they do value-added stuff, they probably are already registeted w/ FDA, and if so, are pretty much going to be subject to the regs.

This is for NY but things might change, unless I hear something different I don't plan on registering.

happy thoughts
01-17-2013, 08:33 AM
As I read it this has nothing to do with who has to register.

What it discusses is which registrants may have to comply with proposed hazard analysis and risk-based preventive control requirements and be required to prepare and implement a written food safety plan.