A trillion here, a trillion there

A good blog to follow the bailout on Wall Street may be Daily Kos: State of the Nation and another Mish's Global Economic Trend Analysis. I'll put Mish's feed into the blog. Here is a sample from the economist Mish:

"We're going to be buying up a lot of mortgage paper" said House Financial Services Committee Chairman Barney Frank.Sadly, that will not do a single thing in and of itself to stop foreclosures. All that will do is bail out banks and brokers at taxpayer expense.Barney Frank also stated “We should be more willing to write down the mortgages. We’ll become the lender. The government will wind up in a controlling position so that we can reduce the number of foreclosures.”Congress needs to ask "How much extra will Barney Frank's proposal cost taxpayers?"Were does the madness end?As stated earlier the problem is not housing in the first place, and besides, taxpayers who pay their mortgages on time should not be subsidizing those who don't!

Paulson wants to recapitalize banks so they can keep lending. Ironically, one of the problems is lending. The US has been on a credit binge to such an extent that I have to ask what more do we need? More Pizza Huts? More Home Depots? More Houses? More Nail Salons? More Car Dealers? What?What is the urgent need to lend still more?We are in this mess because of too much reckless lending. We do not need more lending, we need more saving!Paulson's idea that more lending is needed is ass backwards. Paulson's proposal cheapens the dollar, and discourages the one thing that is desperately needed: saving.

Farm Bureau - Presidential questionaire answered

Thought I would pass along this news release from American Farm Bureau about a questionnaire sent to John McCain and Barack Obama. Here is the summary of the questionnaire and a link to full text:


The American Farm Bureau Federation today released the results of its presidential election questionnaire completed by Sens. John McCain and Barack Obama. In the Q&A document, both candidates responded to AFBF’s inquiries about farm bill implementation, renewable fuels, climate change and death taxes, among other issues.
In the survey, McCain said expanding international trade would be a central focus of his agricultural policy. He said upholding current trade commitments, such as the North American Free Trade Agreement, while working toward ratification of pending agreements with Colombia and South Korea, would be a priority. McCain also supports Trade Promotion Authority.
Obama took the opportunity to discuss his commitment to renewable fuels. He said he has set a goal of having 60 billion gallons of U.S. fuel come from biofuels by 2022.
When asked about the farm bill, Obama said it was important to implement the 2008 bill as passed by Congress. McCain, who did not support the bill, instead focused his answers on expanding foreign markets and reforming the crop insurance program.
According to the survey, both candidates support creating a greenhouse gas cap-and-trade program. McCain goes a step further by saying he would exempt farmers from greenhouse gas caps.
Both candidates pledge to cut the estate tax, with McCain promising a lower tax rate and higher estate value exemption (15 percent and $10 million) than Obama (45 percent and $7 million).
To read more from the AFBF presidential Q&A, visit the Sept. 22 edition of FBNews at: http://www.fb.org/newsroom/fbn/current_issue.pdf

FDA - Issues and questions

Here is the final excerpt from the FDA's notice about upcoming traceability meetings. This excerpt from the document talks about "issues and questions" about produce traceability, and the questions are big ones; do we need a produce identifier?; should all produce be covered?; should produce be co-mingled?


1. Issues and Questions for Discussion
As previously noted, we need to increase the speed and accuracy of traceback investigations to help limit the public health impact of a foodborne illness outbreak; to limit to a particular region, locality, farm(s), or processor(s) the source of the problem (where the source is in fact limited), so that an entire industry is not unnecessarily affected; to enable public health authorities and the food industry to provide targeted and accurate information about affected food to consumers; to institute steps to correct the source of contamination; and, as a result, to restore or enhance consumer confidence in produce safety. We intend the public meetings to stimulate and focus a discussion about mechanisms to enhance product tracing systems for fresh produce and to improve FDA's ability to use the information in such systems to identify the source of contamination associated with fresh produce-related outbreaks of foodbome illness. This discussion will help FDA determine what short and long term steps, such as issuing regulations, we should take to enhance the current tracing system. Aspects of these measures could require new legal authority. We welcome public comments and/or data on the following issues related to product tracing systems for fresh produce:
1. Should a "fresh produce identifier" be assigned to fresh produce? If so, at what stage or stages in the supply chain should such an identifier be assigned or modified? What data or information would be useful to include in such an identifier? Should the identifier be placed on the fresh produce, the package, the shipping container, and/or the invoice or bill of lading?
Should the location of the identifier depend on the type of produce or on other factors?
Our investigations of the 2006 outbreak associated with packaged fresh spinach and the 2007 outbreak associated with peanut butter were greatly facilitated by a product "code" that the party who packaged the implicated product had assigned to the packaged product. We seek comment on whether a "fresh produce identifier" should be assigned to fresh produce, and, if so, at what stage or stages in the supply chain and with what information elements.
2. What other data or information would be useful on the invoice or bill of lading, fresh produce, package, or shipping case? At what stage or stages in the supply chain should such data or information be included? The product "codes" assigned to the packaged fresh spinach associated with the 2006 outbreak and to the peanut butter associated with the 2007 outbreak were present on the packaged products. We seek comment on whether any other data or information (in addition to or instead of the fresh produce identifier discussed in question 1) should be on or attached to the invoice, bill of lading, fresh produce, its package (when feasible), or the shipping case.
3. Should an enhanced product tracing system extend to all fresh produce? Ifnot, what criteria should be used to determine coverage? There are a number of factors that may increase or decrease the risk for contamination of produce. Such factors may include crop characteristics (e.g., proximity of the edible portion of the crop to the soil, or rough surface, such as cantaloupe); production practices or conditions (e.g., water quality for field and packing operations); method of irrigation; likelihood of animal intrusion; and worker health and hygiene. Should these or other factors (e.g., history of outbreaks) be considered in prioritizing the development and application of an enhanced product tracing system?
4. Should fresh produce be commingled? If commingling is unavoidable, what practices should an enhanced product tracing system include to ensure that fresh produce can be traced effectively and efficiently? Some industry food safety guidelines advise against commingling (Ref. 8). Should parties in the supply chain for some or all commodities consider refining or designing their product tracing systems so that they can identify the source of individual pieces of fresh produce if they combine or commingle produce from multiple sources and link this information to the one-up/one down records they establish and maintain? If such identification is not feasible, should parties in the supply chain for some or all commodities consider no longer combining or commingling produce? We seek comment on any measures already in place to address product tracing of commingled fresh produce and the extent to which such measures have been demonstrated to be successful in ensuring product tracing, particularly during traceback investigations.
5. What should be the scope of an enhanced product tracing system for fresh produce?
As stated previously, the supply chain for fresh produce is often complex. We seek comment concerning how an enhanced product tracing system for fresh produce should apply to various parties in the supply chain, including producers, packers, distributors, and retailers. More specifically, we seek comment on whether some or all aspects of an enhanced product tracing system for fresh produce should apply to some or all farms. For example, if a fresh produce identifier includes information about the date of harvest, the farm is the party who would have that information. It may be more practical for the farm to identify the date of harvest on the invoice when it ships the fresh produce than for the first party in the supply chain to subsequently contact the farm to determine the date of harvest. We also seek comment on whether some or all aspects of an enhanced product tracing system for fresh produce should apply to some or all restaurants or retailers. For example, if a "fresh produce identifier" is assigned to produce a restaurant receives, we seek comment on whether the restaurant could establish and maintain records of that identifier or could retain the invoice or bill of lading if the information is contained on those documents. We also seek comment on whether some or all aspects of an enhanced product tracing system for fresh produce should extend to consumers. Product tracing systems currently used by the fresh produce industry typically do not reach the consumer level. However, some segments of the supply chain can and do record some individual consumer information, and may be able to use this information to alert specific consumers about product recalls or for other purposes. For example, a retailer who has a "frequent customer" or "bonus card" program may record each cardholder's purchases. The retailer's consumer purchasing information also would be very helpful in those situations where the fresh produce that is possibly linked to a foodborne illness outbreak is eaten and the consumers have disposed of any identifiers on the fresh produce before a traceback investigation begins. Could such systems be adapted or modified to provide assistance with traceback investigations? Would there be any issues or concerns associated with such systems?
6. Should the data or information in an enhanced product tracing system be human-readable, technology-based, or both? If technology-based, what technology should be used?
"Human-readable" information should enable all parties in the supply chain, regardless of the technology used, to read this information. By "human readable," we mean information consisting of numbers and/or letters capable of being read by the human eye. Technology-based systems could make it faster and easier to accurately record information such as a fresh produce identifier. For example, a person making a paper record of a human-readable identifier expressed in numbers or letters may mistakenly transpose or omit nUIIlbers or letters, thus creating erroneous entries in the records. In contrast, the potential for such mistakes is greatly reduced ifthe identifier is recorded using an automatic system such as a bar code or RFID. In addition, technology-based systems could greatly speed a traceback investigation. However, some parties may not have access to electronic technologies. We seek comment on whether data or information in an enhanced product tracing system should be human readable, technology-based, or both. If technology-based, what technology should be used?
7. What (if any) data or information in an enhanced product tracing system should be standardized? The lack of standardization in the information in current product tracing systems can frustrate traceback investigations. We seek comment on whether the various segments of the fresh produce industry should develop standards for the content and format of records, particularly of electronic records that could help make electronic record systems interoperable. We seek comment on the existence and utility of existing standards relevant to some or all of the information elements that would be in an enhanced product tracing system, such as in a fresh produce identifier. We also seek comment on whether such standards should be developed and on whether current or newly developed standards should be identified in any guidance or regulations issued by FDA. We also seek comment on whether and how current or newly developed standards for the content and format of electronic systems could have practical utility for parties who continue to use paper-based technology. For example, could human-readable data that support standardized technology-based data be useful to parties who continue to use paper-based technology?
8. What are the costs, benefits, and feasibility of implementing an enhanced product tracing system? Further enhancing the product tracing system for fresh produce could aid us in shortening the duration of outbreaks and limiting the number of people who become ill. It could also give us more information to use in preventing future outbreaks. However, these benefits will not come equally from all types of fresh produce. Enhancing the product tracing system beyond current practices and requirements for certain types of fresh produce might not significantly enhance public health if the fresh produce has not been associated with foodborne illness or any known risk factors. An enhanced fresh product tracing system for fresh produce may also impose burdens on entities in the supply chain. We seek comment on the costs, benefits, and feasibility of implementing an enhanced product tracing system for each of the parties in the supply chain. We recognize that enhancing product tracing of fresh produce may not be just a matter of keeping more or different records or adding more information to product or packaging, but also of changing business practices. We request comment on the extent to which an enhanced product tracing system for fresh produce will affect comingling and repacking of produce and the cost of any such changes in the supply chain.
9. Would enhancing FDA's role in developing and implementing effective product tracing systems for fresh produce, through increased regulation, guidance, or additional legal authorities, improve the effectiveness of traceback investigations and traceforward operations? What mandatory and voluntary measures would be most effective in achieving the goal of enhancing product tracing systems for fresh produce and improving FDA's ability to use the information in such systems to identify the source of contamination associated with fresh produce-related outbreaks of foodbome illness? How would these measures help FDA work better with industry and other stakeholders during traceback investigations and traceforward operations?

FDA: international efforts in traceability and what some want in the U.S.

From the FDA notice of the upcoming traceability meetings, more notes on developmenets in oter countries and what some stakeholders are suggesting for the U.S.

G. International Product Tracing Systems Some countries have mandatory product tracing systems in place in various forms, although these systems are more prevalent with respect to animal identification than for food in general. The European Union (EU), in addition to having a mandatory product tracing system for animals, also requires a product tracing system for all food and feed businesses. Specifically, the EU requires all food and feed to be traceable "one step forward and one step back" in EU member states. Food and feed business operators must be able to document where a particular food or feed product came from and where it is going next. Specifically, they must be able to document the names and addresses of suppliers and customers, as well as the nature of the product and date of delivery. They are also encouraged to keep information on the volume and quantity of a product; the batch number, if one exists; and a more detailed description of the product, such as whether it is fresh or processed. Food and feed business operators must also have systems and procedures that allow them to provide this information to the competent authorities on demand. In addition to these general requirements, sector-specific requirements apply to certain categories of food products (fruit and vegetables, beef, fish, honey, olive oil) (Refs. 17 through 20). In 2007, the ED began a 4-year study to develop, test, and evaluate two full pilot product tracing systems-one for the tomato food chain and the other for the feed/dairy chain (Ref. 21). In 2006, Codex established principles for tracing food through production and distribution processes (Ref. 2). The Codex principles are intended to assist government authorities in utilizing product tracing as a tool within their food inspection and certification system. Certain private international standard setting organizations have also developed principles and other guidelines on product tracing systems for use by industry. For example, in 2007 the International Standards Organization (ISO) issued ISO 22005:2007, which provides general principles and basic requirements for designing and implementing a product tracing system along a food processor's supply chain.3 Another example is the GS1 Global Traceability Standard (Ref. 22), which is being used by the PMA, CPMA, UFPA, and other associations involved in the PTI.
H. Actions Suggested by Stakeholders
Some consumer advocacy groups have asked us to develop and implement emergency regulations that would require source tracing for produce (farm-totable); written food safety plans for farmers, processors, and packinghouses; and tighter controls on repacking (Ref. 23). Some industry trade associations have asked FDA and CDC to convene a meeting with industry representatives 3 ISO 22005:2007. "Traceability in the feed and food chain-General principles and basic requirements for system design and implementation." July 2007. Available for purchase at, http://webstore.ansi.org. and work together to minimize the human and economic impact of an outbreak (Ref. 24). These trade associations urged FDA and CDC to work in partnership with industry to find solutions to speed up and streamline outbreak identification and response. These trade associations also recommended that a working group be established to look at crisis management systems and that teams of industry experts be established to help in traceback investigations.

FDA takes measure of industry traceability efforts

From the FDA document annoucing traceability hearings, this passage matter of factly details industry efforts aiming toward traceability, including the efforts of tomato growers, Wal-Mart and the traceability initiative:




F. Industry Product Tracing Systems That Are in Use or Under Development in the United States
1. Commodity-Specific Efforts Various recordkeeping and other practices designed to enhance product tracing systems are already carried out by industry within the food supply chain. For instance, to better monitor food safety practices of growers, the California cantaloupe industry has incorporated product tracing requirements that involve maintaining information such as packing date, field, and packing crew as part of their State marketing order (Ref. 9). Similarly, the California Tomato Farmers cooperative has instituted documentation requirements in its membership agreement with growers to facilitate one up/one down tracking and product tracing. The documentation of packed tomatoes must include information about the source (Le., grower, production location, lot identification, personnel/crew involved in the harvest of the product) and about the customer receiving the product. A system to track and trace tomatoes back to supply source and forward to customers must be developed and tested annually (Ref. 10). Stakeholders have developed commodity-specific food safety guidelines for the entire supply chain for three commodities: Melons (Ref. 11), tomatoes (Ref. 8), and lettuce and leafy greens (Ref. 12).
2. Buyer-Led Initiatives
Large food retailers, such as supermarket chains, have become more active in ensuring the safety of the food products they purchase. One example of this is the increasing use of independent third-party food safety audits of grower and shipper operations to verify compliance with good agricultural and manufacturing practices. These practices generally include requirements that the grower or shipper maintain records that facilitate the tracing of product produced, handled, or processed in order to pass an audit. For example, in February 2008, Wal-Mart, Inc., became the first U.S. grocery chain to require suppliers of its private label and other food products to have their factories certified against one of the internationally-recognized Global Food Safety Initiative (GFSI) standards (Ref. 13). The GFSI standard for traceability requires the supplier to develop and maintain appropriate procedures and systems to ensure (1) identification of any out-sourced product, ingredient, or service; (2) complete records of batches of in-process or final product and packaging throughout the production process; and (3) record of purchaser and delivery destination for all product supplied (Ref. 14).
3. Produce Traceability Initiative (PTI)
In "october 2007, the Produce Marketing Association (PMA), the United Fresh Produce Association (UFPA), and the Canadian Produce Marketing Association (CPMA) initiated the joint PTI (Ref. 15). The PTI now includes more than 50 companies, including distributors, grower-shippers, and retailers. A principal objective of the PTI is to drive adoption of consistent "traceability best practices" throughout the produce supply chain from "field to fork." In pursuing the goal of broad adoption of tracking and product tracing standards and practices, the PTI has established a timeline for a series of milestones for recording, tracking, and product tracing data on produce shipments. These milestones include establishing company prefixes; establishing an identification number for location; assigning global trade item numbers (GTINs) to produce cases; showing GTINs, lot numbers, and packing/harvesting dates on each case; encoding this information in bar codes; and reading and storing the information at each point in the supply chain. The PTI also calls for tracking and product tracing standards to be adopted at the case level initially, followed by standards for item-level coding (Refs. 5 and 16).

FDA to tomatoes: you are no peanut butter or bagged spinach

Okay, they don't exactly say so, but here the agency gives two best case traceability scenarios; more from the FDA document on upcoming public traceability hearings.


E. How Has Product Tracing Information Available in Records and on Product Packages/Containers Helped Us During Traceback Investigations?
In the following paragraphs, we describe how we used product tracing information to conduct two recent traceback investigations-one involving a nonperishable packaged food, and one involving a perishable packaged food. The information available to us included information available in records established and maintained by parties in the supply chain and information available on packages or containers of the packaged food.
• In February 2007, CDC notified FDA of a multi-State outbreak of Salmonella Tennessee infections associated with the consumption of peanut butter. Peanut butter is a nonperishable packaged food, sold in jars. Consumers who became ill had open jars of peanut butter available for testing. Investigators were able to test samples of peanut butter taken from the jars and confirm the presence of Salmonella Tennessee in the peanut butter. Investigators were able to identify the manufacturer through information required to be on the label of the jars (§ 101.5(a)) and through a product code the manufacturer had voluntarily placed on the jars. This information made it possible for FDA to visit the manufacturing facility the day after we learned of the outbreak from CDC. Investigators were able to use the product code to look in the manufacturing facility for unopened jars of peanut butter manufactured at the same time as the jars available from consumers. Investigators took samples of peanut butter from these unopened jars and confirmed the presence of Salmonella Tennessee in those samples. Investigators uncovered conditions at the manufacturer's facility that were likely to have caused the contamination and obtained a positive environmental sample so there was no need to further trace the peanuts back to the farm. Our traceback investigation was facilitated because the implicated food was a nonperishable, packaged food that was available to investigators and contained information about the source of the implicated food on, the product container.
In September 2006, CDC informed FDA of a multi-State outbreakof illnesses associated with the consumption of fresh spinach contaminated with coli 0157:H7. Fresh spinach is a perishable food that may not remain in consumers' homes after consumers become ill and CDC finds an association between the illness and the food. However, in this situation the spinach was sold in a package. The traceback investigation was facilitated because several consumers who became ill still had packages of fresh spinach in their refrigerators. As with the peanut butter, investigators were able to identify the processor through information required to be on the label of the packaged spinach (§ 101.5(a)) and through a product code the processor had voluntarily placed on the package. By looking at the processor's records, the investigators were able to identify the implicated farms associated with the identified production lot of bagged spinach. This traceback investigation was more complex than the investigation for the peanut butter, because it required traceback beyond the processor to the farms. However, as with the peanut butter, the traceback investigation was greatly facilitated by the information on the label of the packaged food and on the package itself.

Traceability meetings - FDA and "challenges" with fresh produce

A United Fresh member communication published this link to an FDA document detailing upcoming traceability meetings. Go to the link to see more detail on the meetings, which will occur Oct. 16 in College Park, Maryland and Nov. 13 in Oakland, Calif. Here is an excerpt from the FDA notice about the "challenges" of fresh produce:



D. Challenges Associated with Traceback Investigations of Fresh Produce
The supply chain for a given type of fresh produce may be very complex. For example, several growers might supply their produce to a packer or distributor, and there may be multiple distributors who receive the product before its sale to or use by the ultimate consumer. Growers may send their 10 produce to several packers or distributors, and suppliers may obtain produce from several packers or distributors as well as directly from growers. Parties in the supply chain may be within the United States or abroad; thus, produce might be imported into or exported from any point in the supply chain one or more times. Other parties in a food supply chain may include processors of fresh produce, who may chill it, cut it into smaller pieces, or combine pieces of fresh produce with other foods to make another food product (such as using lettuce to make a salad). Contamination can occur at almost any point in the fresh produce supply chain. In some fresh produce supply chains, produce from multiple sources may be combined or commingled during packing or processing operations. This practice can complicate or even frustrate efforts to trace fresh produce throughout the supply chain. For example, a packing firm may buy a particular type of vegetable from multiple farms, and then sort the vegetables by size, color, quality, or some other attribute before packing into containers. As another example, a large truck may collect loose produce from multiple farms and then deliver the collected loose produce to a single processor or distributor. Even if we could trace a contaminated product back to the processor or distributor, or, in the second example, back to the packing firm, the commingling of loose produce before it reaches the processor or distributor or at the packing firm makes it difficult or impossible to distinguish which farm is the source of the contaminated produce. The complexity increases if the truck delivers the loose produce to more than one processor or distributor. An additional challenge associated with a traceback investigation for fresh produce is that the produce may not always retain the same description as it moves through the supply chain. For example, one party in the supply chain 11 may describe its fresh produce as "red round tomatoes," while the next party in the supply chain may describe the same fresh produce as "cooker tomatoes." Different descriptions for the same produce can make it very difficult or impossible to determine whether two records refer to the same or different products or shipments. Another challenge associated with a traceback investigation for fresh produce is that there may be no identifier on the produce, its package, or its case, and in associated records. Moreover, there currently is no industry-wide or sector-wide standardization of the information captured in the documentation. This lack of standardization makes it difficult and time consuming to cross-reference information currently available in product tracing systems.

Traceability - meetings coming up

A spokesman for the FDA told me today there will be a public meeting in mid-November in Oakland about produce traceability, and a PMA member communication forwarded me by Julia Stewart adds some details about a similarly-oriented public meeting slated for mid-October in the DC region. Look for complete details with in a Federal Register notice to be published tomorrow.

Meanwhile, Julia notes that the Produce Traceability Initiative is expected to issue a press release by Wednesday or so detailing the group's progress on a timeline and other details.

Third party certification - a power grab by FDA?

What's the verdict on the FDA's guidance on third party certification? Does it make sense to use third parties to help shoulder some of the FDA's responsibility to oversee food safety? Is the FDA trying to gain access to data that it would not have otherwise?

Luis of the Fresh Produce Industry Discussion Group posts a link to some dissent about the FDA's Guidance.

Meanwhile, here is a comment below on the guidance from NSF that points to some of the concern about how the FDA would encroach on relationships between private businesses and third party certification bodies:


A fine line must be drawn here, however, as many companies participate in third party certification programs with the understanding that the information they submit to certifiers, and the findings of the audit, are confidential to the company. However, if NSF discovers a safety issue related to a certified product, it will work with the company to inform appropriate regulatory agencies regarding the product, as well as specify appropriate corrective action.



Meanwhile, from the the comment on the guidance by the Produce Marketing Association, a relevant comment:

Authority to Examine and Gather Records and Other Information – The guidance currently would permit the “certification body and inspectors to examine records and other information relevant to the safety and security of the products for which certification is sought. This should include access to relevant records relating to the producing, manufacturing, processing, packing and holding of products for which certification is sought, including, but not limited to receiving preventative control plans and records, laboratory results, records regarding the upkeep and use of equipment, consumer complaint files and distribution records.”

These general attributes are common to all third-party audits currently used in the produce industry, but it does represent an interesting conundrum in that FDA currently does not have statutory authority to some of these categories of records when performing a routine inspection of a facility unless FDA finds clear evidence that a product is adulterated. Given this apparent conflict, does FDA have a legislative plan that specifically remedies this situation?

It would also be valuable for FDA to expand upon this section to point out more specifically which types of records the agency or an approved third party would want access to and how they will be used in determining the food safety status of the operation. For instance, if a third party should find a violation in a HACCP plan, e.g. in routine hourly readings of free chlorine levels in a vegetable processing wash system where the specified level of free chlorine is documented to be 3-7 parts per million (ppm), and the verification log shows the actual reading for the hour was 2 ppm, how will FDA react to that information? Currently when third-party auditors find an instance such as the example above, their focus is largely on the corrective actions taken by the producer and the verification of those actions. Will FDA work with approved third parties in the same manner, or will the agency view a single HACCP infraction as cause for regulatory action? Will FDA require certified third-party auditors to submit this type of information to the agency as a routine or only when or if that company comes under investigation?

What they are saying about irradiation as a processing aid

The comment period from FDA that seeks public comment on the issue of irradiation as a processing aid for spinach and lettuce ends Sept. 22, and already there are already 40 pages of comments listed on www.regulations.gov. A lot of naysayers, I must say. As I listen to Hank Williams Sr. on my MP3 player(Go and break you crazy heart), I'll list a few of the representative comments below.


From the Annie Appleseed Project:

We represent people with cancer. Most people with cancer go through therapy that includes radiotherapy. They have been exposed to as much radiation as is humanly possible to sustain.

Therefore the trend toward irradiating food products to protect us, will not be helpful to those who have been treated conventionally for cancer. Additionally we, as consumers, believe that the best way to fight bacteria is to have better safety methods at the farm level. It is certainly possible to farm in a healthful way - large factory farms do not practice 'safe farming' but they should be required to do so.

We ask that you focus your efforts toward safe farming and not irradiation.

But if you do irradiate food, we ask that ALL products be clearly labeled in a way that consumers will IMMEDIATELY recognize.

Thank you for your consideration of our comments.

Ann Fonfa,
President
www.annieappleseedproject.org

From Beatrice Whaley:

Please DO NOT use the irradiating PROCESS for our food. We must make the sources more diligent in prevention...........This is an OUTRAGE!!!!!!!...

WE CAN TEACH TO SOAK VEG/FRUITS/MEATS IN 1 GALLON OF WATER TO ONE TEASPOON OF CLOROX WITHOUT COMPRIMISING OUR VALUABLE VITAMINS/MINERALS.

PLEASE STOP!!

From Dr. Goodman

I am extremely opposed to the use of ionizing radiation on food. The research is clear that this treatment of food is unhealthy. (a) I would not eat food treated with ionizing radiation. (b) I would insist that all food treated that way be CLEARLY LABELLED so that I could avoid buying it. (c) I would counsel all my students and clients to avoid food treated this way. I am a Ph.D. psychologist, with extensive training in nutrition.

Dr. Michael Dean Goodman
Boca Raton FL


From Tiffany Calderone:

We are having enough issues getting the American population to mainatain a healthy diet, with out the loss of nurtrition that the use of Ionizing Radiation for the control of food-borne pathogens, and extension of shelf-life.

Please do not advocate and make rulings just to increase economic favor and simplified care over our food. If this is passed this will effect the quality of living in every American. That effect will be negative: decreases nutrition, increased immulagical degridation through tothe point of increased rate of Cancer development.

Tiffany L Calderone, DiHom, PhD
Research Investigator, Dr. Gershenwald's Lab
Dept of Surgical Oncology/Cancer Biology
UT-MDAnderson Cancer Center
7777 Knight Rd, SRB 1.514
Houston, TX 77054


TK: Comments like the above fill the docket. While the "don't irradiate" sentiment is not particularly scientific, it is clear that labeling of irradiated spinach and lettuce is nonnegotiable for many consumers. What's more, there appears to be anti-irradiation sentiment from cancer survivors. Didn't see any industry associations weigh in on this issue so far......maybe Monday?