The CAFF Guide and my 2010 written comments to the proposed Preventative Controls for Fresh Produce, Request for Comment are incorporated by reference and attached as separate pdf’s.
I was encouraged to do a 20,000 foot overview of the proposed Rule, how it fits together and with other rules and laws. It does not look good from 20,000 feet and it looks worse up close.
TK: I would encourage everyone to check out Cohen’s exhaustive comments, which are particularly tough on FDA’s approach to regulating farmers in contrast to FDA’s treatment of fresh cut processing facilities.
Here is the gist, from a 75-page comment:
Farmers are made to pay the price for others’ failures and for systemic failure. The rule treats all food safety as the consequence of individual actions on a farm.There are sufficient hazards to look at on-farm. But there is not a clear outbreak record saying planting to harvest has actually caused many outbreaks. How the FDA ended up in this position is part of the analysis. The short version is: all produce farms in the country are treated as part of HACCP for fresh-cut processing.