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

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

Where crops are very similar in nature, such as apples, pears, and cherries, they should be considered as one crop grouping, or industry, for purposes of the evaluation of risk factors.

Care should be taken by FDA not to broaden food safety mandates beyond the actual demonstrated need. For example, a regulation developed to address a situation involving a vegetable connected to a public food safety incident should not automatically be extended to tree fruits. Different risk factors may be in play and/or tree fruit growers may have better management of their risks based on existing good practices.

It is also important to recognize that there should be a process in place that serves to identify new risk factors that may emerge over time. Similarly, there should be a process to remove or reduce a risk factor that time shows not as important as first thought or where later effective procedures are developed to remove the threat.
Environmental assessment of hazards and possible pathways of contamination:

Growing:
?Tree fruit crops, such as apples, pears, and cherries, have a very low food safety risk profile.
? Orchard floors should be kept clear of commercial flocks or herds of grazing animals, such as cattle or sheep.
? Fruit that has fallen to the ground should not be picked up for human consumption.
?Water can be a hazard if coming from any nearby livestock feeding facility or other such contaminated source.
?Traditional harvest equipment is not a contamination worry in orchards. Our fruit is hand-harvested, not by machine. Ancillary harvest equipment such as ladders and picking bags pose no real food safety issue.

Mechanical equipment, such as tractors and bin-loaders, that routinely go into an orchard at harvest require no prior special pre-cleaning before entering an orchard. It must be remembered that harvest occurs in an open environment and is conducted, at times, under adverse weather conditions, with muddy ground not unusual.

Packinghouse:
?Water in flumes should be clean and monitored.
? Workers who touch fruit need to use and have access to appropriate cleaning facilities.
? Packing line equipment needs regular cleaning.
?Animals need to be actively excluded from buildings where food is stored or handled for processing.


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