The impact of scale of growing operations on the nature and degree of possible food safety hazards:
We think that if a food safety standard is deemed necessary by the federal government to protect the public health, it should apply to any size of commercial operation—big or small.
Methods to tailor preventive controls to particular hazards and conditions affecting an operation:
While careful consideration should be given by FDA to identifying environmental hazards and possible pathways of contamination specific to each crop, the existing USDA GAP guidance program (based on FDA recommendations)—or the simple adherence by growers to those same voluntary FDA recommendations—has worked for our tree fruit industry, as there simply have been no significant food safety incidents reported involving fresh whole apples, pears, or cherries.
For example, in terms of water:
? Microbial testing of irrigation water may be valid and necessary for crops grown at ground level, while unnecessary for tree fruits.
?Rules should recognize special conditions, like flooding.
?Water from an open irrigation canal, which may run for over a hundred miles, is dynamic and a test at one point in time does not scientifically reflect the overall condition of the water.
?There is no evidence of a public health incident being tied to water used for irrigating the trees of an orchard.
Any FDA rule on testing irrigation water should, therefore, be tailored to exclude tree fruits.
Historical lessons derived by FDA from food borne illness outbreaks of high risk commodities should not be extended to tree fruits.
Possible approaches to tailoring preventive controls to the scale of an operation so that the controls achieve an appropriate level of food safety protection and are feasible for a wide range of large and small operations:
We think the best approach is for FDA to give commercial produce growers and packers helpful general food safety guidance, based on the most current science, while reserving specific regulatory requirements to the narrowest range of actions compatible with achieving reasonable levels of ultimate consumer safety. This targeted approach, based on a risk analysis of individual produce items or crop groupings, will lessen red tape for producers while ensuring that real and significant food safety risks are attended to by industry and government. It will also serve to avoid any artificial distinction between small and large producers in terms of food safety protection.