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    FDA Docket on Food Safety Standards

    Julia Stewart:
    Hello, this is PMA PR Director Julia Stewart, and welcome back to PMA’s audio blog, “Ask Dr. Bob”. PMA’s Chief Science and Technology Officer Dr. Bob Whitaker is with me again today. Bob, we currently have a very unique opportunity to shape the future of the food safety regulations that will govern us. Can you explain to our listeners what is happening and what it has to do with them?

    Sure, Julia. As our listeners may recall, I have spoken about President Obama’s Food Safety Working Group and their focus on upgrading U.S. food safety laws, fostering coordination of food safety efforts throughout the various Government agencies that have responsibility for food safety, and ensuring laws are being adequately enforced. We also discussed the resulting Commodity Specific Guidance which was developed for certain commodities in our industry late last year and how FDA would be looking to expand it in the future.

    Well, now we’re at that point!  FDA has announced they are working on a proposed produce Food Safety Rule with an expected release date of this October.  So, we have a tremendous opportunity for input right at the beginning of the process! FDA has announced the opening of a docket to obtain information about current production and packing practices for fresh produce. They are establishing this docket so that interested parties can provide information and share views to help in the development of safety standards for fresh produce, as well as strategies and cooperative efforts to ensure compliance. FDA will use these comments to develop the proposed rule. It’s great to have the chance to get our comments and input in now while the ideas are still being formulated, as opposed to being re-active once the rule is drafted. 

    What exactly are they looking for, do we know?

    Yes, FDA is inviting comments on a number of critical food safety issues, many of which occupy much of our food safety conversations today. They are seeking input on product testing, food safety auditing, the role the agency should play in produce safety, and the intersection of food safety practices and environmental sustainability among other important issues. FDA is also trying to gather industry’s thoughts on how FDA should measure compliance. You know, it’s one thing to comment on setting standards, but it’s a different prospect altogether to have input into how to feasibly implement and enforce those standards. 

    Bob, do you think the agency pays attention to the comments they receive? We invest a lot of time in developing comments.

    I can tell you, one of the key eye-openers I’ve had in my first 2 years with PMA, is to see how FDA really pays attention to these comments, and how writing them has opened up a dialogue between ourselves and FDA. 

    You know, when I first started at PMA I had several opportunities to comment on various FDA initiatives and guidelines.  To provide substantive – and hopefully helpful – comments takes some thought, and most importantly, time.  I found myself wondering if the time commitment was worth it; I mean was FDA really reading what we were submitting? 

    Well, last summer I had the good fortune to participate in a tour the Center for Produce Safety, set up for FDA officials in California.  The tour was designed to help the FDA folks gain a better understanding of agricultural production and what the industry was doing to improve their food safety practices – but it turned out to be informative for me.  During one of our long bus rides down through the Central Valley, I was speaking with a senior FDA scientist about a number of food safety topics only to have her start reciting back to me some of what I had commented on a few months earlier. This led into a very positive discussion on those comments and an opportunity to expand upon them.  In truth, I think she had a better grasp of what I wrote than what I had!  I became a convert right then and there and I truly believe that FDA does indeed review and consider all the comments they receive. 

    Bob, when is it appropriate for our members to comment?

    Our listeners should check out the Federal Register notice, Volume 75, number 35 posted on February 23, 2010 on page 8086.  Provide comments on those questions or topics where you have experience or a point of view that can give FDA some valuable, constructive input. You can find a link to the Federal Register notice at our food safety page on www.pma.com   

    PMA will be submitting written comments as well, and as always, we appreciate any input you might have for us. Just email me at askdrbob@pma.com.  I’d also like to take this chance to thank those who have offered helpful comments in the past. I greatly value the interaction I have in talking with people around the industry.

    Thank you, Bob, for giving us more background on this important public comment opportunity – and to hear your personal experience that we are in fact being heard.
    Listeners, we do encourage all of you to take a look at the FDA docket and seriously consider submitting some constructive comments that will help them in their process of writing the Proposed Produce Food Safety Rule. Again, for more information on this, go to www.pma.com and look for the food safety page under the Issues tab.

    Thanks to our listeners, and please join us next time!

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