Link-o-rama: Prior notice rule, child labor, food safety preventive controls, booming ag exports and red hot apple prices - The Packer

Link-o-rama: Prior notice rule, child labor, food safety preventive controls, booming ag exports and red hot apple prices

09/01/2011 09:25:00 AM
Tom Karst

It is link-o-rama today at the Fresh Talk blog, and i know you will find something you are interested in.

Check out the comment of Lance Jungmeyer and the Fresh Produce Association of the Americas on the FDA's prior notice rulemaking.

An excerpt:

In adding the requirement to give notice, if any, of a country to which the article of food was given prior refusal, the FDA must develop a clear way for regional offices to consistently base admissibility decisions on the condition of the refusal.  Issues that affect the safety and security of a food product are of the upmost concern to our industry and to FPAA. .  Preventing port shopping and creating standardized rules across the border are important in enhancing the safety of the U.S. food supply and we support this goal..
 
It is important, though, that this new requirement not become a trade barrier.   Just because another country may refuse entry for a product does not mean that the refusal was necessarily appropriate for food safety or security.  In fact, the foreign country refusal may not be in accord with NAFTA or WTO and should not be relevant to US entry.  For example, many countries deny entry to US exports of food products that the FDA and USDA approve as completely safe for US consumers.   If US apple exports were denied entry to Japan for being waxed but Korea and the US were willing to accept the apples, the US would argue that the Japan refusal should not be relevant.   FDA must treat imports in the same manner the the US government demands that its trading partners treat US exports.

The PMA and Bob Whitaker also has made available their comments on the FDA rulemaking on preventive food safety controls for produce. From the 18-page document:

From the doc:

As indicated already, it would not be prudent for FDA to prescribe preventive controls regardless of the size of the operation. Instead, the company’s specific risk assessment/hazard analysis plan should become the guide as to which preventive controls should be employed. Again, FDA should strongly consider issuing guidance in this area to help all companies determine the range of preventive controls they might employ to manage identified potential risks. No matter the size, basic measures such as providing training for worker hygiene, wash water sanitation, facility and equipment sanitation and supplier qualification apply to all operations and can help assure food safety.


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