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

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

The potential enormous collective costs to our growers and packers of any FDA required regular microbial testing program at orchards and packinghouses are not justified when weighed against such testing’s probable ineffectiveness in protecting the health of the ultimate consumer.

Post-harvest operations and the role of the current good manufacturing practices in 21 CFR part 110:

Most tree fruit packinghouses have established HACCP plans appropriate for their operations. As indicated in 21 CFR 110.5 close attention is paid to ensure that finished products are moved and packed under conditions that would minimize potential contamination and not render it injurious to health. Though many of the regulations associated with 21CFR 110 are more applicable to processed food, fresh tree fruit packinghouses are cognizant of good manufacturing requirements and employees are trained with food safety in mind.
Records and other documentation that would by useful to industry and regulators in ensuring the safety of produce:

As a practical matter, a commercially workable product traceability system is in place in our tree fruit industry, which requires systematic record keeping by firms.

Aside from this, we do note that the current legal liability system in our country serves to discourage any grower or packinghouse from keeping additional detailed records related to food safety as such records are subject to an intrusive judicial subpoena power at the sweeping command of any private litigator.

It should also be stated that most growers are involved in farming because they want to avoid being clerks, accountants or bureaucrats. Forcing detailed and time consuming food safety record keeping tasks on these people will lead to no good outcome. Only the bare minimum of necessary record keeping requirements should be imposed by the federal government.

EPA and state regulations already require that growers maintain records concerning type of pesticide application; application rates and times; and environmental conditions, such as wind speed. The remote potential of pesticide contamination related to food safety is already adequately and effectively regulated.

Strategies to enhance compliance:

The best strategy for compliance is to have an easily understood regulatory system that is focused on actual and significant food safety dangers. It should be flexible to change, given advances in scientific knowledge.


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