NHC to FDA: microbial testing for human pathogens should not be required of tree fruit

07/25/2010 11:22:12 PM
Tom Karst

On the latter point, certain Washington state orchards that were the source of fresh fruit exported to Mexico received a regulatory oversight visit by three officials of Mexico’s SENASICA during the period June 27 to July 6, 2010. It was the first official food safety visit to individual orchards in our industry and, we believe, prompted by increased U.S. government activities related to food safety within Mexico.

While it is too early to evaluate the practical results of this particular visit, it is clear to our industry that greater and more effective official communication and coordination in terms of new fresh produce safety policies needs to occur between our country and the governments of our major trading partners.

Commercially important foreign inspection issues such as those related to reasonable notification of the time and method of inspection; language to be used (e.g., Spanish or English?); technical food safety standards to be applied; the possibility of the acceptance of equivalency with various existing food safety standards; and clarity on the range of possible penalties for exporting firms that may be in some level of violation need thoughtful and respectful bilateral negotiations.

For its part FDA needs to recognize the need to actively engage its fellow federal agencies, such as the United States Department of Agriculture’s Foreign Agricultural Service and the Office of the United States Trade Representative, in coordinating its mission of ensuring the safety of imported foods while taking into account the reasonable concerns of other countries. Clear lines of responsibility for the handling of the technical trade issues related to produce safety are needed within our own government.

Finally, FDA should identify and then provide an appropriate level of assistance to domestic produce growers faced with responding to on-site food safety inspection demands of foreign governments.

Identification and prioritization of risk factors:

Consideration of risk factors for growing and packing methods should be commodity specific and initially done at the industry level using the best available science as a base and following national guidelines as set by FDA.
Each industry will know best the diversity of growing and harvesting methods, climate conditions, transportation, commercial packing processes, and other factors so intertwined with possible food safety risk.


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