Part II - WPPC - FDA meeting on Sept. 11 - Amy Green

As promised, more from the WPPC-FDA meeting of Sept. 11. We are near the beginning of the 90 minute plus program, where a panel of about five or six FDA officials speak before answering questions. These are the remarks of Amy Green.

From her bio:


Amy Green has been with FDA’s Center for Food Safety and Applied Nutrition for eight years. She is policy analyst in the Office of Food Safety, and has been lead author for fresh-cut produce safety guidance.

Her remarks:

Welcome.. I see at least half of you have smiles on your faces, so I guess that's a good a sign. (laughter) Michelle told you that I would talk to you about the produce safety initiatives. I’ll start out with the produce safety initiatives.

There are two. The leafy greens safety began in September 2006 in the Salinas Valley in California. The tomato safety initiative began in June 2007 on the eastern shore of Virginia. Now these initiatives represent relatively new approaches for FDA. They are allowing us to visit a broader range of operations in non-outbreak situations.
At the same time, the initiatives are part of a risk-based strategy designed to reduce foodborne illness by focusing our food safety efforts on specific products, practices and growing regions.
The objectives of the initiatives are to assess current conditions and practices, the challenges that are (faced) by those conditions and practices and responses to those challenges, and also to enhance collaboration between the FDA, state/local governments and industry.
The information that we gained from the initiatives will be used to improve our understanding of current practices and provide data to inform policy decisions and future guidance that we write.

In 2006, the first year of the leafy greens initiative, assessments were conducted at farms, packing houses and fresh cut facilities in the Salinas Valley. In 2007, we narrowed the focus to environmental factors, particularly animals and water. San Benito County and Kern County were assessed, we spent a good deal of time before we went out to the field identifying the sites where we would visit. To identify specific locations were we would visit, we used Geographic Information Systems or GIS. We used GIS to map out where certain environmental factors appeared to converge the most often: with followed up (the use) of GIS with aerial photography to confirm what we had done with GIS and to further help our site selection so we could use our resources most efficiently.
The tomato safety initiative began on the eastern shore of Virginia in June 2007. The assessments done as part of the tomato initiative addressed growing, harvesting and packing practices. Thus far, two of the three parts of the tomato initiative have been completed and we just want to say that Florida growers have given us unprecedented cooperation throughout the initiative and we hope that will continue.

The success of these initiatives is due in large part to the collaborations with state partners, academia and industry.

Another produce activity that Michelle mentioned was FDA conduct of microbiological sampling survey that started in 1999. (The survey) is done on domestic and imported fresh produce commodities. In 2008 survey, we are sampling fresh whole cantaloupes, leaf lettuce, tomatoes, green onions, spinach, basil, cilantro and parsley. We are analyzing for salmonella, E. coli O157H7, shigella, Hepatitis A and cyclospora.
Throughout the years, we’ve made changes to these surveys; changes to commodities, pathogens and analytical methods. For example, in 2005 we added fresh spinach to the list of commodities and we added testing for Hepatitis A and cyclospora and changed the methods for detecting salmonella in potatoes and tomatoes because (the new method) improved accuracy of testing.

The surveys that we do are conducted for surveillance; we are basically trying to collect a body of data on incidence of contamination in select produce commodities.
In addition, if positive samples are found, regulatory follow up provides us the opportunity to observe practices and conditions that may be associated with contamination.

We start with same basic survey with domestic and imported product but some differences exist because it is unavoidable. One of the differences is that for domestic produce we can collect the sample close to the farm as possible, whereas for imported produce, we have to collect data at the port of entry. So that’s it for me. Jack will speak next.

Part 1 : Sept. 11 WPPC-FDA Meeting Michelle Smith

From the FDA-WPPC session of Sept. 11, we are joining the program barely in progress. Michelle Smith of the FDA speaks to WPPC attendees about rulemaking on GAPs and encouraging input....

From her bio:
Michelle is an interdisciplinary scientist with FDA's Office of Food Safety. She led the development of FDA's 1998 GAPs guidance, and had a leadership role with the 2004 Produce Safety Action Plan. Prior to coming to FDA, she was served on the faculty at the University of Maryland.

From Michelle Smith:

"On Sept. 2, the FDA published a Federal Register notice looking for information and data to help us update the 1998 good agricultural practices guidance. I think that the principles that were established in 1998 stood the test of time. Our experiences implementing that GAPs guidance, and certainly the experience of folks in industry trying to implement the GAPs guidance; have given us some ideas of the things we might improve. Working with the commodity specific work groups in a technical capacity has given me a chance to see how some of the thinking has changed.
The Federal Register notice has a list of questions to help focus comments; you are not bound to only comment on those questions, but they are intended to give you an idea of the kind of information and data we are looking for.
Again, what we ultimately do can only be as good as the information we have to work with; that’s my personal appeal to look at that and to the extent you can provide (input) to help make that better, please do.”

COOL Comments - AWG, Earthbound Farm and Infratab

Country of origin labeling is mere days away, but both the industry and the public aren't done with their comments about the rule. Here is a post today from Earthbound Farm seeks to clarify - and perhaps narrow - the categories of "covered commodities."


To Whom It May Concern:

Earthbound Farm (EBF) appreciates the opportunity to submit the following to the U.S. Department of Agriculture (USDA) regarding its request for comments on mandatory country of origin labeling (COOL). We applaud the USDA’s response to consumers’ request that country of origin be listed on the foods they buy. As the nation’s largest grower and shipper of organic produce, EBF believes it is in the best interest of the public - and our industry - to educate consumers on the origin of the products they are buying.

EBF offers the following suggestions as ways to enhance and clarify the specifics in the Final Rule.

Labeling of Commingled Products:

EBF supports the agency’s ruling in §65.300 and §65.400 that a single commodity, chopped Romaine lettuce for example, from multiple countries of origin that is commingled can be labeled by listing each of the countries involved.


Definition of Processed Product:

EBF recommends that any fresh-cut produce item, even those not combined with another substantive food item or other covered commodity be included in the definition of “processed product” (§65.220). By taking a raw agricultural commodity, washing it, then cutting it, a company does change the product from a raw agricultural commodity to a ready-to-eat food item. Fresh-cut vegetables could be compared to cooking a raw meat product, which changes it to a ready-to-eat food.

Definition of Covered Commodities:

We support the agency’s Interim Final Rule that designates that items with distinct varietal names, within a generic category of products, be deemed different products and excluded when two or more are combined.

We ask the agency to offer more clarity about combinations of covered commodities in the definition of “processed product.” When speaking about generic categories of products (lettuce, melons, etc.), different varieties within those generic categories are distinctly different. There is some confusion over whether or not a bag of mixed leafy greens, for example, would be considered a covered commodity because it consists of several varieties.

If processed commingled products, such as bagged specialty salads, are ultimately categorized as covered commodities (subject to COOL), we will need clarification on what percentage – if any - of a product in a mix requires a COOL designation. In other words, is there a minimum of sourced product that would make it exempt from the rule?

Effective dates:

USDA states that the requirements of this rule do not apply to covered commodities produced or packaged before September 30, 2008. Many in the industry procure packaging materials for a year’s worth (or more) of production. Given the short amount of time between the release of the Interim Final Rule and the effective date, we ask that companies subject to the rule be given a year from the effective date to use up existing packaging inventories, provided those packaging inventories were acquired prior to the effective date of the rule.

Thank you for considering the above comments. EBF appreciates the agency’s efforts not to impose economic inefficiencies or disrupt the orderly production, processing, and retailing of covered commodities. We agree that should such disruptions occur in our manufacturing, the increased cost of our products will most likely be passed on to consumers. By clarifying the definitions listed above, and upholding parts of the rule that we support, EBF will be able to continue producing healthy, affordable products for consumers.

Respectfully Submitted,


Charles Sweat
President
Earthbound Farm



TK: Here is another comment published today, with a technological if self-serving twist from a company named Infratab:


Regarding comments on COOL for Perishables:
It is possible to use an RFID label that will convey Freshness by a percentile number of the actual shelf life of the Produce. We supply such a tag now to an FDA Pilot n Hawaii--and have done so in the past for cut-fruit from Africa to Holland..New Readers for UHF EPC Global Gen 2 Tags make reading such labels at up to 200 cases per minute possible--but also
Pallets at any rate normal to their handling speed. On a Pallet basis such a tag adds about $1.00 to an entire pallet of cases and provides an accurate and immediate indication of shelf -life parameters being exceeded as well as the custody at the time of the event....In the absence of such specialized readers a push button overide on the tag substitutes and signals
a Good/Bad equivalency but with no percentile until a reader reads it.Still a packer might start such tags by hand and only use readers at minimal DC and Shipper points .

Request the COOL committee mention this in it's report and allow further time and perusal for investigation of such a tag's value. It allows instant inspection of a violation and attributes it to the proximate factors. Such a system can save time , money , labor, and lengthy insurance disputes-- and should be part of the COOL requirement.



TK: Finally, from Associated Wholesale Grocers, a questions about labeling of salad:

A question has come up in regards to salads.

We have a Value Added Pkg Caesar Salad

Contents are: Dole Caesar Dressing in an envelope, Garlic Croutons in a pkg, Parmesan Cheese in a pkg, Romaine Lettuce

Since it only contains romaine lettuce and the product has not been mixed or processed, shouldn't it be covered under the COOL regulations. As of right now, our understanding is that it is not because it contains dressing. I question why not as it is only fresh Romaine lettuce and not mixed together.

President Bush - On the crisis

If you dare: Chiquita chandelier - DIY

A really offbeat opportunity for the do it yourselfer:

There's been a world-wide banana shortage since early 2008, and some have even predicted that the banana, as we know it, may become extinct. While you still can, you may want to create a memorial to the tasty, nutrient-rich banana, with this DIY project from Dutch designer Anneke Jakobs - The Chiquita Chandelier! Ms.Jakobs, made design news when she created the Chiquita Chandelier out of recycled Chiquita cardboard shipping boxes in 2003, but she has just released instructions for creating the Chiquita Chandelier yourself... if you can.


The downloadable diagrammed instructions look complex to me, but if you are up to the challenge, go for it. Of course, the PDF downloadable version is easier to see.

You may want to start asking your local grocery stores to save Chiquita banana boxes for you.

Download PDF instructions for Chiquita Chandelier here.

In the category "Timing is everything"

Food safety lawyer Bill Marler writes in an email from China:

Well, the food safety conference did not turn out quite how the host country intended – timing is everything. The below might be helpful. I am in Beijing until Saturday:

http://www.marlerblog.com/2008/09/articles/case-news/china-food-safety-conference-begins-and-ends-on-sour-note/


Our Fresh Produce Industry Discussion Group has a batch of new posts this morning you will want to check out, including a post about irradiation of spinach and lettuce, a link to a story about the privileges of China's elite (Let them eat organic) and a post with coverae about alleged collusion in some sectors of U.S. agriculture. The Packer has coverage of record low Florida citrus acreage and a late start for Argentina blueberries.


I have a call into Rep. DeLauro's office about when she will drop her promised food safety reform legislation.....