Thirty six thousand, three hundred and forty three. That’s how many comments that the FDA has received (as of July 30) on the monumental proposed regulation titled “Standards for the Growing, Harvesting, Packing and Holding of Produce for Human Consumption.”
According to the terms of a settlement between FDA and the Center for Food Safety and the Center or Environmental Health, the agency is supposed to issue its final rule for the produce safety rule by Oct. 31. Before that — sometime this summer — the agency was expected to issue a revised draft regulation.
Well, the clock is ticking, and there are 36,343 ways to Oct. 31 that will make that deadline a real challenge for the FDA.
For your review, here are a few links to comments on the produce safety rule:
The definition of a raw agricultural commodity (RAC) and a Farm are intertwined, so much so that a RAC produced on a farm might no longer be a RAC due simply because it was carried 100 feet to another farm. This creates a confusing, illogical circle and does nothing to increase food safety quality on that RAC. Instead, a RAC should officially transform when it’s been changed by processing (at which time it would become part of the Preventive Control Rule). Otherwise, it should remain a RAC and a part of the Produce Rule, regardless of who owns it, until it is appropriately changed by processing.
We urge FDA to reconsider standards that take into account the relative risks and comparative benefits associated with individual commodities. FDA should initially propose regulations for only those commodities with a history of microbial contamination. If these regulations can be successfully implemented and enforced, it may be appropriate at that point to consider whether there is a net public health benefit to be gained from expanding regulations to cover other commodities.