ACS needs to present a strong and unified voice to FDA. To do this, we need your help. Please consider sending your own response to FDA by posting directly to the Federal Register. Need ideas as to what to say? Here are some ideas as to how you might focus your response:  

(1) Share your personal concern over the economic impact that any regulatory changes may have on your business.  

For example:  

For producers: "As a small producer, I worry that any changes in regulation based on this risk assessment could inordinately impact businesses like mine. For example, if I were required to test five lots from each batch I produce, my annual costs could exceed $xxxx." (To estimate impact, multiply $200 -- 5 tests at $40 inclusive -- by the total number of batches you produce annually.)

For retailers, distributors, or others: "While I realize this is only a risk assessment, I am concerned that regulations may stem from this report that will have a grave economic impact on small producers. This will make it much more difficult for my business, which depends on a strong population of small cheesemakers, to stay afloat."

 (2) Ask FDA to incorporate more specific real-world data into the risk assessment.  

For example:

"I am an artisan/farmstead/specialty cheesemaker, and I would like to request that this risk assessment incorporate some real-world data from producers like me, rather than merely extrapolating data based on isolated research."

"FSMA encourages innovation in safe food production. As such, FDA should consider multiple types of interventions -- particularly those that are widely accepted in other countries, and have been proven effective in actual cheesemaking operations. For example, xxxx". (Include intervention strategies that you (for cheesemakers), or the cheesemakers you work with (for retailers, distributors, and others), might use to reduce the risk of illness, such as thermization, micro-filtration, phage, etc.)

Thank you for your support,

The American Cheese Society