Never mind.
In April, the Association of Independent Banana Producers of Guatemala submitted a petition to the Food and Drug Administration, stating the group’s objections to the Food Safety Modernization Act’s water standards - and asking for modifications.
In late September, the group walked back on their earlier petition, asking it be considered “canceled” or null and void . They did this, I believe, because FDA/federal authorities are still wresting with water safety standards. At least that is my rough, Google-enabled translation of the Sept. 23 letter.
An official English version of the April 5 letter, published on regulations.gov listed some of the concerns associated with the FSMA water standards and asked for modifications to sections related to testing of E.coli in water, water quality monitoring, and application of untreated water to produce crops.
The petition explains why the exclusions/modifications to the water regulations are being sought:
The production of Banana in Guatemala is located and concentrated mainly in the area of the country known as the Costa Sur and /or Litoral del Pacifico.
It is a border territory with the Pacific Ocean (South), with El Salvador (East) and Mexico (West) covering the territory of the departaments of San Marcos, Quetzaltenango, Retaihuleu, Suchitepequez, Escuintia, Santa Rosa and Jutiapa, with an altitude range between 0 and 3,000 meters above sea level.
Banana farms are established between O and 500 meters above sea level, which places them on the lower part of the basins of the Pacific Ocean, where the surface water of the different rivers reaches their river mouth after they have passed, without receiving any type of treatment, for hundreds of villages upstream, so that when passing to the height of the banana farms, the water of these rivers in general, presents a degree of contamination mainly by E.coli, from the discharges of wastewater generated by referred population centers. Pollution that varies according to the river and the time of year.
It has even been claimed that at least 90% of surface waters in Guatemala are contaminated with feces (Mosquera, 2017, cited by Basterrechea et al., 2018:386).
Therefore, as there are large rivers, for farms that use the water from the rivers as a source of irrigation, by means of engines installed on the riverbanks of rivers, from where the water is pumped to be distributed to the irrigation systems by means of channels that have other engines for distribution, it is untenable and unaffordable to comply with the requirements of the Standard in its Section 21 CFR § 112.44 (b) and (2), which forces to give a treatment to these waters, to guarantee that it maintains a geometric mean (MG) of 126 or less colony forming units (CFU) in 100 ml of water and a statistical threshold value (VUE) of the samples of water with 410 or less generic E.coli UFC in 100 ml of water.
But is water treatment necessary for bananas? The petition describes various experiments where bananas were subjected to heavy doses of the E. coli virus, but because of the protection of the peel, no fruit was ever contaminated.
From the petition:
In short, the results allowed to demonstrate the capacity of the banana, mainly by the characteristics of its peel at a biochemical level - such as the antibacterial and antioxidant activity that occur in the green banana peel - to resist the entrance of the bacteria to its edible part. Which adds value if it is considered that historically there has never been any case reported of contamination by E.coli in banana.
And the economic costs of treatment of irrigation water would be severe, the petition states:
The economic consequences of the water quality standard proposed in §112.44 (a) (2) can be quantified from the construction of the microbiological profile requested in §112.44 (b) for water sources for agricultural use.
FDA reports that the cost of a sample conducted to quantify E.coli in water can vary between USD $87.30 and USD $120.05 (Wall, G., Clements, D., Fisk, C., Stoeckel, D., Woods, K. & Bihn, E., 2019: 5)
In fact, in Guatemala to perform the test by method 1103.1 EPA-821-R-10-002, contemplating transportation costs and sampling time is quoted at approximately USD $150.
It should be considered in addition, most farms operate with two or more sources of surface and underground water. A single sampling campaign for a banana farm could cost USD $ 600 and should be repeated five times a year, meaning around USD $3,000.
All in all, banana producers in Guatemala are looking for direction from the agency:
The objective of the guild is to comply with the Food Safety Modernization Act and guarantee an innocuous banana for the consumer, which is being achieved through the implementation of good practices in the field and in post harvest, so that investments in water treatment, would not change said production system, but it would damage the ability of producers to sustain decent jobs for the more than 30,000 direct employees who benefit from banana plantations members of APIB.
TK: The FDA has its hands full in completing work on water standards. Witness Guatemala banana producers and their arguments, and then multiply those variables by thousands more. Is “never mind” an option for FDA?
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