Organic Trade Association to FDA: three main concerns about food safety regulation
Published on
07/25/2010 10:37PM
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From the FDA docket on preventive controls for fresh produce comes highlights of a submission from the Organic Trade Association....
The Organic Trade Association (OTA) would like to thank the Food and Drug Administration for this opportunity to provide information and share our views to help inform the development of safety standards for fresh produce at the farm and packing house and strategies and cooperative efforts to ensure compliance. OTA is a not-for-profit 501(c)(6) trade association representing over 1200 organic businesses across the supply chain in the US and Canada. OTA strongly supports improvements in food safety and supports the preventive approach taken by this notice.
OTA has three main concerns regarding this regulation.
1) We understand this is rulemaking focuses on prevention of contamination, but we would like to stress that this regulation should be consistent with 7 CFR 205 (the National Organic Program), including not requiring the use of any prohibited materials or practices.
2) We would like to avoid duplicative efforts where possible, including recordkeeping and inspection. Organic agriculture is the most highly regulated system of agricultural production in the U.S., and the USDA-accredited verification system, especially its recordkeeping and inspection requirements, should be recognized and considered by FDA when drafting rules requiring similar features.
3) We would like to note that issues may vary according to production method and scale, and urge FDA to be cautious when considering one-size-fits-all regulations. Finally, we note that USDA’s Agricultural Marketing Service is also engaging in efforts regarding the safety of fresh produce, and we provide for the record OTA’s position on the organic agricultural system and food safety.
Steps taken to ensure regulatory compliance can be considered “organic control points” similar to the “critical control points” considered in hazard analysis. Some of these are detailed and directly transferable to food safety issues, such as the documentation of the non-use of prohibited materials and the plans for compost and manure management. With these systems and documentation protocols in place, the organic system offers an integrated process approach to preventive food safety practices that could stand as a national model for both farming and manufacturing operations. The organic process already contains many steps that contribute to food safety processes and it can be easily integrated into a more elaborate food safety system – especially in processing.
Thank you very much for your consideration.
Best regards,
Christine Bushway
Executive Director
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