Ms Scarlet Harris

Microbial Safety Div= ision

Food Standards Agenc= y

London

20 December 2007

Dear Ms Harris,

I am writing on behalf of the Welsh Agrifood Partnership Organic Horticulture sub- group = to comment on the Partial Regulatory Impact Assessment produced for the Food Standards Agency’s Guidance on Managing Manures for Food Safety.=

· = The Sub gr= oup supports the publication of the guidance (Option 2) as voluntary code of practice.

· = However we= would like to stress that were the guidelines to become regulatory at some point = in the future, there are areas that could prove problematic for organic grower= s. I refer you to our original response (attached for ease of reference) for det= ails.

· = Of greatest concern is the 12 month exclusion of stock f= rom fields destined for ready to eat crops. This will place considerable restrictions on mixed organic systems that rely on grazing livestock to bui= ld fertility – a practice widely accepted as contributing to sustainable agriculture. As well as incurring severe financial penalties on existing gr= owers, the restrictions could curtail the growth of the organic sector in this are= a. Increasing the proportion of local and organic produce is a stated aim of m= any recently published Welsh Assembly Government policy documents including the Organic Action Plan; the ‘One Wales’ document; Quality of Food Strategy; and the Appetite for Life action plan.

· = We welcome= the emphasis the guidance places on effective composting and the role it can play in reducing the risk of contamination

David Frost

Chair, Welsh Agrifood Partnership Organic Horticulture sub- group<= o:p>