Letter: FSMA counter-terrorism rule needs industry input

01/03/2014 09:49:00 AM
Christian Schlect

Tell it to The Packer | Letter to the Editor

Christian Schlect, president
Northwest Horticultural Council
Yakima, Wash.

Another in a string of proposed rules implementing the Food Safety and Modernization Act was published Christmas Eve: the Food and Drug Administration’s proposed rule entitled “Focused Mitigation Strategies to Protect Food Against Intentional Adulteration” (Federal Register, Dec. 24).

In essence, the proposed rule seeks to prevent acts of terror in food facilities: heinous crimes aimed at killing or otherwise injuring numerous members of the general public and throwing our nation’s food system into chaos.

As with the other proposed FSMA rules, there are several exemptions. Here, most notably and reasonably, all farms are excluded, along with simple food storage facilities.

Also, those food firms with under $10 million in annual sales are exempt. However, this leaves most of the nation’s commercially important produce packinghouses within the boundaries of the proposed rule.

This means a produce packinghouse would need to prepare and implement a written “food defense plan.”

It would require coverage of actionable process steps, focused mitigation strategies, monitoring, corrective actions, verification, training and record keeping.

Special attention is directed by FDA at bulk liquid receiving and loading, liquid storage and handling, secondary ingredient handling, and mixing and similar activities.

My first thoughts?

  • The produce industry is already awash in food safety requirements and crawling with auditors.

  • Existing legal liability already serves to vividly remind owners of the need for reasonable security at their operations.

  • Produce, which is normally shipped by the truckload and then later sold in small amounts to retail customers, would not seem to be a high-value target for terrorists.

  • There is no prior example of a successful major terror event involving produce.

  • The high economic cost in terms of continual employee training and compliance outweighs the sliver of a theoretical benefit.

  • As imports are covered, this will further complicate our overseas trading relationships.

  • Sadly, the only ones likely to be eventually apprehended and tried will be those who fail to comply with FDA’s new regulation requiring a food defense plan. (Convicted packinghouse owners will probably be sent to Guantanamo Bay.)

Members of the produce industry need to read this proposal. Comments are due by March 31.



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