We object

06/17/2009 04:22:56 PM
Tom Karst

 -- FDA Recall, Cease-Distribution and Quarantine Authorities: The Bioterrorism Act requires FDA to detain a product if FDA has credible evidence or information indicating a product is adulterated and presents a threat of serious adverse health consequences or death to humans or animals. This bill would lower that threshold that requires that FDA only have a “reason to believe” that a product is adulterated, misbranded or otherwise in violation of the bill. This should be revised to allow affected firms to voluntarily recall products before FDA issues a mandatory recall. If a “cease distribution” or quarantine provision is retained in the bill, it must require that FDA have a reasonable probability, based upon scientific risk assessment, that the product in question will cause serious adverse health consequences or death to humans or animals. Given the heightened emphasis on government accountability, the bill also should mandate that FDA indemnify affected growers and facilities that sustain economic damage resulting from erroneous FDA recall and quarantine orders issued under these sections.
 
-- Country-of-Origin Labeling: The bill requires all non-processed food products (which would encompass raw agricultural commodities, like grains and oilseeds) to identify the country-of-origin of the product. This labeling also would apply to products of U.S. origin. This section must be removed from the bill. Country-of-origin labeling is not a food or feed safety issue. This is particularly true given the bill’s other requirements that foreign facilities and suppliers exporting products to the United States meet the same food/feed safety standards as domestic facilities. Its implementation would be onerous and extremely costly to business and consumers alike, particularly for products containing numerous ingredients from numerous countries.
 
While each of our groups may have additional specific concerns with other sections of the bill, we have attempted to limit our concerns to the eight major provisions on which we all agree, and strongly urge that the bill be amended to address these serious deficiencies during full committee markup. We would be happy to meet with you at any time to discuss these concerns.
 
Sincerely,
 
American Farm  Bureau Federation
American Feed Industry
 Association American Soybean Association
American Sugar Alliance
Corn Refiners Association
 National Association of Wheat Growers
 National Barley Growers Association
 National Chicken Counci
l National Corn Growers Association
 National Grain and Feed Association
 National Milk Producers Federation
 National Oilseed Processors Association
 National Pork Producers Association
 National Sunflower Association
 National Turkey Federation
 North American Millers’ Association
 Pet Food Institute
USA Dry Pea & Lentil Council
 USA Rice Federation
 US Canola Association
 


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