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Issues: Food SafetyPMA Comments to USDA on ANPR For Leafy Greens Marketing Agreement December 3, 2007 The Produce Marketing Association (PMA) is pleased to submit these comments to the Agricultural Marketing Service (AMS) regarding the advance notice of proposed rulemaking (ANPR) that considers the establishment of a marketing program, with USDA oversight, to implement regulations for the production and handling of leafy green commodities. PMA is the largest global not-for-profit trade association representing companies that market fresh fruits and vegetables. Our 2,200 members range from grower-shippers and supermarket retailers, to hotel and restaurant chains and overseas importers. Within the United States, PMA members handle more than 90% of fresh produce sold at the consumer level. PMA and its members are committed to improving food safety practices for produce, both domestic and imported, to further enhance the safety of our food supply. Federal Oversight of Food Safety PMA’s general position on food safety oversight, as previously communicated to USDA, is to support federally mandated, risk-based, commodity-specific regulation of fresh produce, building on the steps already taken at the state level with the California Leafy Greens Marketing Agreement (CLGMA) and more recently, with the Arizona Leafy Greens Marketing Agreement (ALGMA). PMA recognizes that the procedure to put a federal regulatory framework in place may require a multi-stage approach, and advocates regulations by the Food and Drug Administration (FDA) as the final goal, while supporting an AMS marketing program as an interim step to implement uniform minimum standards that are enforceable by the federal government. Given that FDA has primary jurisdiction over food safety for produce, harmonization between USDA and FDA would be critically important to the success of an AMS marketing program. Uniform Standards for Domestic and Imported Produce It is critical that any federal regulatory framework be applied uniformly to domestic and imported produce. To ensure uniformity with respect to minimum standards, the best practices adopted pursuant to an AMS marketing program should take precedence over any conflicting requirements at the state level. Commodity-Specific Standards PMA supports the establishment of minimum handling requirements at the federal level for specific commodities, based on the best available scientific evidence and the risk profile identified for those items. Given the great differences in growing conditions and safety considerations for specific commodities, general handling requirements would not be effective or justifiable for all commodities. Regional Differences An AMS marketing program should contain minimum commodity-specific handling requirements that cover all regions, with the flexibility to include additional standards, as necessary, to address any regional issues that could potentially impact safety. Regional subcommittees that report to national committees would be useful in expediting the resolution of issues unique to particular growing areas. Key Goals of an AMS Marketing Program A key purpose of an AMS marketing program, in addition to maintaining quality by reducing the risk of pathogenic contamination during production and handling, should be to restore and enhance consumer confidence in the produce industry, and in the federal government’s oversight of produce safety (USDA and FDA). It is PMA’s overriding goal for consumers to have confidence in the safety of all leafy greens they purchase, and to have those commodities produced under the same safety standards. Best Practices Criteria for a Marketing Program The establishment of Best Practices for an AMS marketing program should start with an examination of FDA’s Guide to Minimize Microbial Food Safety Hazards in Fresh Fruits and Vegetables, Guide to Minimize Microbial Food Safety Hazards in Fresh-cut Fruits and Vegetables, and other FDA guidance, as well as the CLGMA and ALGMA metrics. The participation of industry in the development of marketing programs standards would be invaluable, as it has been in the development of FDA guidance and the leafy greens state marketing agreement metrics. Moreover, the importance of basing safety requirements on the best available scientific evidence cannot be underestimated. In this regard, PMA and the University of California recently created the Center for Produce Safety (CPS) at the University of California, Davis, for the purpose of funding research on produce safety, maintaining a database of relevant research worldwide, developing outreach programs, including food safety training at the farm, packing and production levels, and disseminating information concerning public health issues related to produce. AMS, during the process of developing marketing program standards for specific commodities, should consult with the CPS regarding practical research findings and training that promote food safety and that should be considered for incorporation in the standards. Covered Leafy Green Commodities With respect to the leafy green commodities to be covered under an AMS marketing program, PMA recommends that the commodities presently subject to the CLGMA and the ALGMA be included at the outset, with periodic reevaluation. Prioritization based on relative risk should be used in expanding the scope of an AMS marketing program to additional commodities. Marketing Agreement PMA agrees with AMS that it would be best to start with a marketing agreement. A marketing order may be considered by AMS, at a later time, if supported by industry. Thank you for the opportunity to present these comments. We look forward to working with AMS if a marketing program is to be developed. Bryan E. Silbermann, CAE President, Produce Marketing Association
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