What’s more, he said FDA has devoted considerable time evaluating what are considered “high risk” crops based on epidemiological data, but that process turned out to be difficult, Kraemer said. For one thing, he said the risk of any crop has as much to do with how much of that crop is consumed as it is by the risk of any particular commodity.
In addition, using contamination data by testing particular commodities is problematic. For one thing, the FDA doesn’t have a lot of contamination data. The other reason is that testing can be a self-fulfilling problem. “If you think you have a problem with cucumbers and you start testing cucumbers, you will probably find problems with cucumbers but if you haven’t chosen cucumbers you probably never find a problem with cucumbers,” he said.
Two significant challenges are apparent to evaluating risk based on agronomic practices, he said. One of those issues is the application of raw manure, and the time needed between application and harvest. The other is water directed to the edible portion of the crop and how that correlates safe harvest practices.
So the FDA has no easy task. In particular, I wonder how the FDA will devise a regulatory framework that is meaningful to grower operations of varying size throughout the country.
We shouldn't be surprised, I supposed, that the FDA wants to avoid targeting of particular commodities as "high risk." That would be a millstone for growers and invite litigation.
The industry will have opportunity to see more of the FDA's thinking when they publish the proposed produce safety rule. How soon that will be a is a question, however; Kraemer said the FDA's work on the produce safety rule is running later than the Congressional mandate of early 2012.