LaBorde to FDA: GAPs education efforts fragmented

From the federal docket on GAPs this morning, a thoughtful letter from Luke LaBorde to the FDA, expounding on the need for follow through and education of growers after updated standards are issued. From the docket:



Luke F. LaBorde Ph.D.
Associate Professor
442 Food Science Building
Department of Food Science
College of Agricultural Sciences
The Pennsylvania State University University
Park, PA 16802-2504
(814) 863-2298 Fax: (814) 863-6132
email lfl5@psu.edu


April 3, 2009
To whom it may concern:

As an Associate Professor and Extension Specialist in the Penn State Department of Food Science, I have been actively involved with food safety issues at all levels of the food system; production, processing, retail and food service, and consumer. Because Pennsylvania is the primary producer of mushrooms in the U.S. (approximately 65% of all domestic common white mushrooms are grown in the state), I have collaborated with the American Mushroom Institute to develop food safety standards for mushroom growers. These standards, known as MGAPs, are based on, and are consistent with, the general GAP recommendations contained within the "Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables". The MGAP program provides the basis for a recently approved mushroom farm food safety audit administered by the USDA AMS Fresh Produce Audit Verification Program. Recently I have extended my work in farm food safety to include growers of other crops in Pennsylvania. With support from the Pennsylvania Department of Agriculture through the USDA Specialty Crops Block Grant Program, I have developed curriculum materials and presented training sessions including a 1-day video conference workshop broadcasted to 20 county locations across Pennsylvania. The targeted audience was 380 produce growers and packers pre-identified as suppliers of national and regional grocery stores located in Pennsylvania. Among the workshop hand-outs was a Farm Food Safety Plan template designed to assist growers with the difficult process of documenting their farm food safety practices. My experiences in planning and delivering this program tells me that farm food safety requirements handed down by wholesale produce buyers will increase greatly in the next year and that educators must be prepared to assist growers as they develop farm food safety plans and prepare for third party audits. Below are a few thoughts on the Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables and plans to update and revise it.
Although I have been actively involved with developing commodity specific GAP standards for the mushroom industry, I do not believe that this approach is always the best one. We felt it was necessary to interpret the Guide in the context of the unique methods used to grow mushrooms so that produce buyers and third party
auditors would understand cultivation procedures, potential hazards associated with them, and what the industry is doing to minimize risks. For instance, the safe use of animal-manures as an ingredient in mushroom growth substrate was justified by Penn State research that demonstrated that the standard industry active composting process was adequate to eliminate human pathogens. However, for most commodities, the general guidelines in the current FDA “Guide” are largely adequate to address farm food risks. If a particular commodity group or individual grower believes that a GAP standard in the “Guide” isn’t applicable to their crop, it should be their responsibility to conduct a science-based risk assessment and propose effective risk management strategies. In much the same way that a variance for specialized processing methods may be granted to the FDA Food Code, a commodity group or grower could generate data that would qualify them for a variance to the general GAP standard. This risk-based approach would help to bring industry, academia, and government together to identify, prioritize, fund, and conduct produce safety research. Another key component in assuring safe produce is education and training. When the “Guide” was first published in 1998, a USDA conference entitled “Toward Implementing the Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits & Vegetables” has held. The purpose of the conference was to identify the education needs of growers relative to the four major sections of the “Guide” namely water, manure, sanitation, transportation and handling. Although much has changed and several groups have developed training materials and held GAP workshops, there has not been a similar conference in the 10 years that have elapsed. Several academic institutions have created training materials and conducted training sessions. But these efforts are fragmented and initial well-funded efforts seem to decline as their grant support expires. Farm food safety as a national issue has increased dramatically in the last several years. Clearly it is time to create a mechanism for discussion among extension educators and the industry to identify “best practices” in educational methods and to foster continued national discussion and sharing of ideas.