Proposed rules: More questions than answers?

01/16/2013 04:59:00 AM
Tom Karst

For example, the QAR ranked certain produce commodities, such as bananas and coconuts, as lower risk for illness, in part because such commodities are peeled or shelled before consumption in a manner that can be expected not to transfer contamination onto the interior, edible portion of the commodity. Should such commodities be covered by the rule? Is coverage of these commodities unnecessary? Should they be covered but subject to a less stringent set of requirements?

Some commodities (for example, pears, grapefruit, oranges, and lemons) meet both of these criteria, considering the rankings and outbreak data used in the QAR. Should commodities that meet both of these criteria be covered by the rule?

Is coverage of these commodities unnecessary? Should they be covered but subject to a less stringent set of requirements?

How should the rule address the changing nature of outbreak data over time?

 How should the agency account for uncovered commodities in considering a commodity-specific approach that relies on outbreak data? 

Are there pathogen surveillance data from sampling programs focusing on produce commodities that have no history of known outbreaks that would be useful in considering a commodity-specific approach?

Can commodity characteristics be used as a basis to consider a commodity-specific approach?

While the outbreak data show no consistent pattern that can be matched to commodity characteristics such as growth habit, our QAR shows that produce commodities that are ranked as higher risk of illness and those ranked as lower risk of illness do share some of the same characteristics.

A further refinement of our assessment might be helpful in developing a commodity-specific approach based on commodity characteristics. Considering the qualitative nature of our assessment, are there quantitative data sets available that would enable a further refinement of our assessment?

Are produce in both direct market channels and other commercial channels subject to the same routes of contamination?

Is the number of opportunities for contamination during packing and holding greater for produce in other commercial channels as compared to produce in direct market channels?

If yes, is this due to greater numbers of touch points and handlers in these channels than there are in direct market channels, or to other factors?



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