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

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

There is no zero risk. Economics do have to be considered even in food safety.

Coordination of produce food safety practices and sustainable and/or organic production methods:
We do not see any reason why either sustainable or organic production should have any different food safety rules than those employing conventional agricultural production techniques.

If a federal standard is deemed necessary by FDA to protect the public health it should be applied uniformly.
If organic or sustainable agriculture standards are in conflict with any true food safety requirement, then the organic or sustainable agricultural standards should themselves be adjusted to accommodate the serious public health need.

Another point: in the tree fruit part of production agriculture, it is not unusual for a grower to have certain acreage in organic production and other acreage in conventional. It would not make sense to have one orchard be subject to two different FDA food safety mandates.

Coordination of produce food safety practices and environmental and/or conservation goals and practices:
Conservation and environmental practices do not have a direct effect on food safety. While social issues should not be allowed to muddy the science, government does have an obligation to take into account other priorities of our society when assessing the overall value of certain of its food safety regulations. We are not proposing that other priorities or goals be grafted on to food safety regulations: we would strongly oppose this as improper for FDA. We do say that sometimes a secondary food safety point should be trumped by a greater need in another public policy area, such as wildlife preservation.

Our growers take pride in growing premium fruit along the great rivers and aside the towering mountain ranges of the Pacific Northwest. Not only is it not necessary in terms of food safety, it is a violation of the spirit of this landscape to destroy the habitat of wild animals, or wantonly kill animals not posing a significant threat of harm to our fruit.

Federal food safety standards actually requiring such things as the fencing of orchards, mandating clear-cut buffer zones, or prohibiting a grower from having a farm dog’s steady companionship would be abhorrent—in the absence of any clear scientific showing of actual health risk to the ultimate consumers of our harvested tree fruits.


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