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

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

Coordination of produce food safety practices and Federal, State, local and tribal governmental statutes and regulations:
Through the U.S. Constitution’s Commerce Clause, our country benefits from a vital asset—a national market place. Consumers expect safe food from whatever the source. A patchwork of different food safety requirements for the growing and packing of fresh produce is unneeded and would be decidedly unhelpful.
If a food safety measure is required by the FDA for a certain produce crop, this federal measure should preempt any state, local or tribal rule or regulation attempting to cover that same ground.

Having said the above, we are open to the question whether once a standard has been set by FDA, implementation or enforcement work might be done in cooperation with sister federal agencies, such as USDA, or state governments.

Microbial testing:

Microbial testing for human pathogens should not be required by FDA of our growers and packers since to our knowledge, commercially handled whole fresh tree fruits have never been implicated in any significant food safety incident related to human pathogens.

Regulations for testing processed food should not be applied to fresh produce at packinghouses since, with whole fresh apples, pears, and cherries; there is no multiple product mixing/blending, whereby contaminated ingredients might possibly be introduced into the process. And, choosing several pieces of fruit from a packinghouse sorting line to test will never provide adequate assurance that there is no contamination present.

Meanwhile, any mandatory microbial testing would invariably lead to false positives and negatives, directly resulting in unnecessary product destruction and severe economic loss.

If some scientifically-proven system of microbial testing should be developed and ever required by FDA to be used to verify the effectiveness of preventative control measures, it will need to be determined—before general implementation—if such testing is warranted for all types of produce and for all stages of each individual crop’s growing and handling. What might be reasonable for a crop raised at ground level, or in the soil itself, probably would not be reasonable for one grown high off the ground on the limb of a tree.

It should also be pointed out that adding significant costs (for example, those related to sampling, record keeping, and laboratory test fees) and operational complexities, especially at the orchard level, will invariably lead to greater economic pressure on small scale producers leading to more industry consolidation, i.e., fewer but larger orchards.


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