Julia Stewart:
Hi, this is PMA PR Director Julia Stewart, and welcome back to PMA’s audio blog, “Ask Dr. Bob.” Chief Science Officer Dr. Bob Whitaker is with me today to talk about new commodity specific guidelines currently being developed by FDA.

Bob, FDA has just recently released the draft Commodity Specific Guidance for tomatoes, melons and leafy greens. So, what does this mean for those commodities and for our industry in general?

Bob Whitaker:
Julia, these current actions are rooted in a long history of work by industry to minimize food pathogens in our products. Back in 1998, FDA issued guidance to minimize the risk of pathogen contamination in fruits and vegetables which has now become known as Good Agricultural Practices or GAPs. Later, the industry and FDA recognized there were some crops that seemed to have repeated food-borne illness outbreaks associated with them, like tomatoes, certain types of leafy greens and melons. So the FDA asked the industry to develop commodity specific GAPs to try to identify what it is about those particular crops that makes them more susceptible to outbreaks and what can be done to reduce the likelihood of an outbreak. These three commodity groups worked diligently, with input from FDA, to develop their commodity specific GAPs.

This July, at President Obama’s Council for Food Safety, FDA officials announced they would be coming out with Commodity Specific Guidance for these three crops, and on August 1 the agency released draft guidelines for tomatoes, melons and leafy greens. These documents should be very familiar to most of the produce industry, because FDA has basically taken the documents industry developed, made some changes based on what we’ve learned recently, and put them out as the draft guidance.

We now have the opportunity to review and comment on these draft guidelines until November 2, to find where they are weak, overly prescriptive, or don’t make any sense for our industry. PMA is working with commodity groups and members to gather input, and working with other trade associations and regional groups to make sure we properly reflect the industry’s perspective. Then we’ll prepare and submit comments to FDA. Generally, FDA weights these comments and then makes changes where they see fit based on the feedback. This process will take at least a year, maybe two. After the comments are submitted, PMA will most certainly meet periodically with FDA to answer any questions they have and provide any technical information they need.

Right now, both the GAPs as well as the Guidance FDA is working on are VOLUNTARY. Industry is asked to use these when developing their own food safety programs, and many of the auditing companies use these guidelines as a basis for their audit checklists. However, there is also a lot happening on the legislative front. The Waxman Bill has cleared the House of Representatives, and the Senate will likely take action on food safety legislation this Fall.  This is important because much of what we see as guidelines today could eventually become regulation tomorrow, so we need to follow all of this very closely and carefully. PMA’s government relations blog Field to Fork is a great way to keep on top of what is going on legislatively. You can find them online at: fieldtofork.pma.com

Julia:
Thank you, Bob. This is definitely an issue PMA will be watching and updating as things progress. Listeners and readers please do give us your comments. Thanks very much to our listeners, please join us again next time!

Julia Stewart:
Hello, this is PMA PR Director Julia Stewart, and welcome back to PMA’s audio blog, “Ask Dr. Bob.” Chief Science Officer Dr. Bob Whitaker has been discussing in recent posts the various aspects of building a food safety culture, and challenging the industry to look at food safety from a different perspective.

Bob, I know you get asked frequently about the ins and outs of product testing. How does product testing fit into the food safety culture you’ve been describing? What are the pros and cons?

Bob Whitaker:
Julia, we could have a whole host of posts on the positives and negatives, and the do’s and don’ts, of product testing and what it all means. But the top line is that you need to look at the uses for testing in your operations and consider how testing helps you manage risks.  Understand that testing is only a tool; you cannot test your way to food safety.  Unless you have the proper risk assessment and risk management practices in place and working properly, testing is meaningless.

These days, we are confronted with the need to test water, soil amendments, process environments, equipment surfaces and even seeds.  You need to look at how these efforts relate to your risk assessment and risk management goals, and then determine whether testing these factors will help you manage the risk better or if the tests will help verify the effectiveness of a process.  Similarly, in the last few years pressure to test raw and finished products has increased.  Again, you must understand what these tests can and cannot tell you, and work with your customers to develop the smartest testing program; one that helps you manage potential risks, and one that gives them greater confidence in that risk management program.

Know also that testing can get expensive. I have seen instances where meeting certain testing requirements can add as much as a dollar in costs to a box. Buyers and sellers have to ask themselves if that is the best use of their money to improve food safety. Regardless of where you stand on testing today, one thing is certain: testing methodologies have improved dramatically over the last few years, and research is being conducted now that should help us develop more statistically significant sampling programs. Eventually, costs will equilibrate and accuracy and significance will improve, and that can only help our industry in the future.

We also talked about testing in a post we made last year, on June 10, 2008 – I invite our listeners to check it out for more discussion on the limitations of product testing.

Julia:
Thank you, Bob. I think there’s definitely a perception out there that testing ensures safe product, when we know that trying to find some of these pathogens is like trying to find a needle in a haystack. This is an important topic our members should consider as they work to continuously improve their food safety programs.

Thanks very much to our listeners, please join us again next time!