2004N-0258 - Produce Safety from Production of Consumption: An Action Plan to Minimize Foodbourne Illness Associated with Fresh Produce; Public Meeting
FDA Comment Number : EC1
Submitter : Mr. Todd Wichmann Date & Time: 07/19/2004 05:07:36
Organization : HealthPro Brands Inc
Food Industry
Category :
Issue Areas/Comments
Questions
2b. What intervention strategies will prevent, reduce, or control this contamination?
A produce wash that consumers can use at home contains a natural anionic surfactant, or fatty acid, will contain the same cleaning properties as a soap solution, which is just basically a synthetic fatty acid, and therefore provide the same antimicrobial properties to ensure produce is safe and clean to eat. There are also several produce washes that come in a concentrated powdered form which can kill pathogens in the home when produce is soaked for several minutes in a highly acidic environment.

This is NOT just a theoretical argument - sound, scientific data supports this strategy. There are several outside 3rd party research studies that have appeared in scientific publications that prove the effectiveness of produce washes vs. washing with water alone. These articles can be found at:

Journal of Food Protection Vol. 64 No. 2 2001 Pages 152-158

Journal of Food Protection Vol 64 No. 8 2001 Pages 1103-1109

Journal of Food Protection Vol. 64 No. 10 2001 Pages 1477-1482

4b. What measures should be used to measure progress toward the individual objectives?
CDC illness reports relating to produce
1a. What concepts or underlying principles should guide the 2004 Produce Safety Action Plan?
I'd like to challenge the FDA's assumption in your background statement for the public meeting held on June 29, 2004. Specifically you state, 'The fact that produce is often consumed raw without any type of intervention to control or eliminate pathogens prior to consumption contributes to its potential as a source of foodborne illness.'

This is a FALSE assumption, and highlights the key reason for me writing to the FDA. I would also like to point out that this statement is basically admitting on behalf of the FDA that water alone isn?t good enough to clean produce by itself.

But there IS a solution for consumers and should be addressed by the FDA ? namely the use of a natural and safe produce wash.

Everyone (consumers, FDA, CDC, etc.) knows that washing your hands with water alone to remove pathogens is not as effective as washing your
hands with soap and water. I would stipulate that this fact is an axiom in food handling & safety and can not be challenged. In fact, the FDA is going out of its way to emphasize the need for workers and handlers of produce to wash their hands with soap and water before touching produce in the current safety guidelines.

However in the same guidelines, the FDA recommends to wash produce with water alone before consumption. How can these two positions make sense when compared to each other? Common sense dictates that consumers need to use something else besides water alone to ensure their produce is really clean, for the same reasons consumers need to use something else than water alone to wash their hands with.

It is practically impossible to eliminate produce contamination completely, and given the nature of how produce is grown and eaten, it is also practically impossible to inspect every field, distributor, or farmers market. However, the underlying principle for the proposed 2004 plan should be to EMPOWER CONSUMERS TO SANITIZE THEIR PRODUCE AT HOME THEMSELVES.
4a. What measurements should be used to measure progress toward the overarching goal (to minimize foodborne illness associated with fresh produce consumption)?
Measuring the CDC reports of outbreaks of foodborne illness - success will only be acheived if these reported illnesses from produce significantly decrease over time.
3a. Should the produce action plan cover additional foods?
No
5b. If yes, please describe generally the areas that need expansion or other revision.
The FDA needs to focus their new guidance on the HOME environment and what steps can consumers take AT HOME. No matter how well the FDA can ensure the production and handling of safe produce at the farm and distribution center level, the fact that produce is handled by many people in a store before it is eventually purchased means that consumers need to be able to clean and sanitize their produce at home to help ensure thoroughly cleaned produce. In fact, I would encourage the FDA to focus on the home environment in their Produce Safety Plan more than any other point in the distribution chain since that is where the greatest impact can be made to improve the public?s health. If produce is thoroughly and properly sanitized at home, then every other potential problem in the distribution chain is immediately reduced.
1b. Are the seven objectives in the working draft appropriate for achieving the overarching goal to minimize foodborne illness associated with the consumption of fresh produce?
The current objectives are good, but there is an objective CLEARLY missing from the proposal. Specifically, there should be a new objective that would state, ?Provide new recommendations to consumers to improve produce cleaning in their homes.? In this new objective consumers should be told there IS a way to help ensure produce is really clean by recommending consumers wash all their fruits and vegetables with a produce wash prior to consumption.
2a. What major practices contribute to the contamination of fresh produce by harmful pathogens?
The issues that contribute to produce contamination have been well documented and others can better describe them than I can. However, since there are so many ways produce can be contaminated before it is eaten raw, cleaning and sanitizing produce AT HOME by CONSUMERS is the only real practical solution to this growing problem.
5a. Does FDA's current GAPs/GMPs guidance need to be expanded or otherwisse revised?
Yes, as previously stated, the FDA should recommend that ALL consumers use a produce wash to sanitize their produce at home before consumption. These produce washes should be made with ingredients that are 100% safe to be used on food and are listed on the FDA GRAS list
for food use.

Based on internal company research, about 25% of consumers are already using a product to clean their produce with, but unfortunately a lot of these consumers are using un-safe products such as hand soaps, bleach, or dish liquids. As the FDA correctly states in its guidelines, these chemical cleaning products should NOT be used on produce since the chemicals in those products are not safe to be used on food and are not safe for human consumption.

Since consumers are already recognizing on their own that water alone isn?t good enough to clean produce with, the FDA should set clear guidelines as to what products they SHOULD use, namely a product specifically designed to wash and clean produce with safe and GRAS approved ingredients. It is in the public's best interest for the FDA to make this clear to consumers on what products they should be using.