GLOBALGAP is an interested party when it comes to FDA's rulemaking on preventive controls for fresh produce safety. Here is the comment recently submitted to FDA on the federal docket.
Comments on Docket No. FDA-2010-N-0085
Comments to inform the development (1) Safety standards for fresh produce at the farm and packing house (2) strategies and cooperative efforts to ensure compliance.
• Standards for domestic and foreign growers and packers
GLOBALG.A.P believes that domestic and foreign growers and packers should and can comply with the same standards. National interpretation and adaptation to local legislation may need to apply within a pre-defined range.
Since 1996 GLOBALG.A.P has with input from stakeholders and many experts developed global standards for Independent third party certification of GAPs on farm.
This is a cooperative effort driven by the private sector to ensure compliance on farm. Annually 100 000 producers undergo ISO65 controlled verifications in more than 100 countries. It is welcomed by the public sector in many jurisdictions as a complementary food safety effort to National and International legislation. The standards have established a good track record in preventing microbiological and chemical contamination of produce.
The standards are made freely available at www.globalgap.org under “Standards” and are commended to you for further review. The fourth version of the standards with updates on best practices to prevent microbiological contamination will be published in October 2010.
• Possible Approaches to tailor preventative controls to the scale of an operation so that controls achieve an appropriate level of food safety protection and are feasible for a wide range of large and small operations
• Coordination of produce food safety practices and environmental and/or conservation goals
GLOBALG.A.P certification is carried out in developing countries with export horticulture in mind and includes certification of smallholder farmers. GLOBALG.A.P has developed guidelines to facilitate the implementation of GAPs by small farmers. Some developing countries e.g. Kenya, supported by Government, are adopting a pared down GLOBALG.A.P standard for the national market as an interim step
Compliance and cost efficiency is assisted by the ability for growers to opt for group certification. Groups can provide capacity building and quality management systems to assist in achieving compliance. Further information/resources on Group certification can be found at www.globalgap.org