FDA should reconsider FSMA regulations - The Packer

FDA should reconsider FSMA regulations

04/26/2013 09:42:00 AM
Chris Schlect

Regulatory efforts and scarce resources ought to be directed to actual food safety problem areas, such as what the FDA itself projects to do with its proposed special rules for the growing of sprouts.

Fruit growers do not ignore food safety. We fund additional research and are supporters of the Center for Produce Safety.

We take reasonable actions already, such as keeping herds of domesticated animals from wandering about orchards (As Dr. Johnson said in the 18th century, “A cow is a very good animal in a field, but we turn her out of a garden.”); not picking up grounders; having sanitation facilities readily available to workers; and being alert to threatening activities, such as threats that may be posed by any neighboring cattle feedlot.

These and other commonsense measures can be, and are, the subject of food safety guidance from the FDA. If there is any new and effective practice found that reasonably protects the ultimate consumer, it will be adopted cheerfully.

Finally, unintended consequences to the structure of our industry should be a concern.

Here, all the very smallest produce growers have been exempted by way of a $25,000 revenue test as well as many other smaller growers that only sell within a certain geographical range (the Tester Amendment).

The little farm goes on as before, even though many a past serious food safety event has sprung from small produce operations.

The biggest of farms have the resources to hire food safety experts, handle recordkeeping and pay for tests and procedures.

Meanwhile, the average family orchard is in the middle — most of these commercial operations already have over-extended owner/managers, many other rules and regulations to fret over and obey, and no surplus of cash.

How will these orchards, the traditional backbone of our nation’s tree fruit industry, survive the FSMA?

Chris Schlect is president of the Northwest Horticultural Council, Yakima, Wash.

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Ken Nye    
Lansing, Michigan  |  April, 30, 2013 at 01:14 PM

Chris, Your comments are spot on. We have plenty of concerns with the proposal from both the a cost standpoint and practicality. Michigan has about 4000 fruit and vegetable growers. Probably 2000 would be covered by the proposed rule. FDA has estimates annual compliance costs of $5000 to $30,000 per year based on size. So the potential cost of compliance will be more than $10 million, likely $20 to 30 million per year. Yet most major produce commodities grown in Michigan have not, and likely will not, be associated with food safety issues. Is it reasonable to cause an industry to spend millions of dollors on compliance when virtually no public good will result. At our in-state Listening Session last week, FDA did a nice job of explaining the basics of the proposal and responding to questions. I came away from that meeting feeling that the agency had listened to concerns expressed at the earlier sessions (I also attended the Chicago session back in March). The agency indicated that they wanted to hear from commodity sectors that believe they should be exempted (non covered). This was news to me, and FDA addmitted that. They also indicated that they wanted to know if growers should be required to be registered. Wow, that is a loaded question. We also had quite a bit of discussion about wildlife contaimination and about produce that could be utilized either fresh or processed, depending on the year and market considerations. As you noted in your opinion, we are also very concerned about the international consequences. A Canadian representative was at our listening seesion, and Canada is already smarting over our unfair livestock and meat product COOL requirements.

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