Public comment: GAP guidance

Comments aren't due until Dec. 31, but the first opinions are arriving in the federal docket about the notice announcing possible FDA revisions to Good Agricultural Practices. This comment is from an anonymous student.


The FDA has created three guidance documents for the best practices of handling fresh produce, too much latitude has been given in the area of irrigation water testing and safety. In the guidance document, Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables, the FDA identifies the sources in which water supplies can be contaminated, but does not require or insist on regular basic testing of fecal coliform, caused by poor sewage or animal contamination which is the most common cause of microbial contamination. Under the Clean Water Act, specific testing for fecal coliform has been mandated to ensure the safety of clean drinking water. However, the same contaminates have been directly linked to microbial foodborne illnesses outbreaks within the Untied States directly tied to contaminated irrigation water supplies. There needs to be a review of the exclusion within 21CFR 110.19 that specifically excludes agricultural handlers to eliminate the storage of fresh produce in unsanitary conditions. Contaminated irrigation water being the unsanitary conditions presented and not regulated. The Clean Water Act is too specific and should not be implemented on agriculture water supplies some of the basic testing of fecal coliform should be addressed and mandated to ensure the safety of fresh produce at its source, the farm or harvesting location.