I will use this space to publish a variety of comments submitted to the FDA on its proposed rule docket "Preventive Controls for Fresh Produce; Request for Comments."
This was submitted May 25 by Brent Harrison about the place of watermelon in produce safety:
Brent Harrison: The watermelon industry is in the process of submitting comments to the FDA docket to help FDA obtain information about current practices and conditions for the production and packing of fresh produce (watermelon).
As an industry, we are concerned about food safety requirements and rules as they relate to our crop. While the industry agrees with GAP and GHP standards of food safety, and is one of the most proactive and progressive in its approach, we believe that our suggestions would improve the utility and clarity of produce standards, consistent with FDA?s intentions.
The Melon Category A High Risk Priority: The Melon category has a high risk designation, or category of priority, as identified by FDA for the category?s history of produce outbreaks. The Melon category (by FDA definition) includes Cantaloupe (also known as Muskmelons), Honeydew, Watermelon, and variety Melons (e.g., Canary, Crenshaw, and Galia).
In a letter dated January 22, 2010 from FDA to the National Watermelon Association, FDA stated, ?melons have been linked to 15.9% (13) of the eighty-two food-borne illness outbreaks associated with the consumption of fresh produce between 1996 and 2008 in which FDA was involved (i.e., outbreaks not associated with contamination at point-of-service).
Cantaloupe was involved in 10 of the 13 outbreaks associated with melon consumption. Of the remaining 3 outbreaks, 2 were linked to honeydew melon and a third to pre-cut melon, type not specified. FDA?s outbreak data for fresh produce during this time period does not reflect any illness outbreaks linked to pathogen contamination of watermelon during production, harvest or packinghouse handling?.
Industry customers (retailers and foodservice operators) require "additional" and "unnecessary" investments in food safety audits and procedures because of the High Risk designation, even though Watermelon has a clean record. The added costs are substantial; they are in addition to standard GAP and GHP investments; and these costs are fully borne by the watermelon industry with no pay-back from our customers.
The High Risk designation is not deserved and the resultant costs of wasted time, labor, and money are forcing some farmers to move to other crops. Even as a safe crop, we are considered by our customers to be "guilty by association" and are forced to pay an additional, unnecessary price.