Another serious concern United has with the proposals is the small-farm exemption.
By its own economic analysis, FDA says such an exemption could result in more than 400,000 additional cases of foodborne illnesses every year.
If the object of the new law is to make our food supply safer, and to bolster consumer confidence in the process, having a huge loophole in the standards doesn’t make sense.
If eventually enacted with this small farm exemption, produce buyers might be wise to procure product only from operations that meet the new food safety standards, regardless of farm size.
Another realization from United’s FSMA review process is that FDA desperately needs data to help provide support for the direction they’ve taken in the draft rules.
In so many cases, these proposed rules represent a new frontier of food safety, especially when applied across a variety of commodities, production cultures and other variables.
More than ever, it’s clear that implementing FSMA will have to be a highly collaborative process, involving regulators and stakeholders at every level.
That’s especially true when you consider that we’ve not yet seen FDA’s proposals for regulating foreign supplier verification and accredited third-party certification. All the FSMA regulations, once in effect, will be interrelated in some way or another.
Perhaps never before in our industry has such sweeping and technical rulemaking been so transparent, and FDA deserves a lot of credit for that. They’re clearly working to improving produce food safety on a global scale.
It’s incumbent on all of us to anticipate the many details of this historic process and make sure they get it right.
Ray Gilmer is vice president of issues management and communications for the Washington, D.C.-based United Fresh Produce Association.
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