2004N-0258 - Produce Safety from Production of Consumption: An Action Plan to Minimize Foodbourne Illness Associated with Fresh Produce; Public Meeting
FDA Comment Number : EC7
Submitter : Mr. Lee Frankel Date & Time: 07/28/2004 11:07:32
Organization : Fresh Produce Association of the Americas
Food Association
Category :
Issue Areas/Comments
Questions
1a. What concepts or underlying principles should guide the 2004 Produce Safety Action Plan?
As you are aware, FPAA has worked closely in the past with FDA on GAPs issues pertaining to cantaloupe, and we look forward to continuing to work with you on this broader initiative. In the context of the cantaloupe review, we have discussed our suggestions on traceback issues, but would like to repeat those suggestions here. We believe that an FDA and CDC visit to several commercial operations would allow epidemiologists and investigators to see first hand the variety of commercial records that are currently maintained as a standard practice. The lack of familiarity with these records has limited the effectiveness of some historic trace back, and training of these systems would definitely improve future trace back investigations.

Further, with regard to traceback, FPAA suggests that the Perishable Agricultural Commodities Act offices of USDA have experts with extensive expertise on the requirements of commercial agents for U.S. importers of fresh produce that identifies the origin and disposition of virtually all fresh produce by lot number that would assist the FDA.

FPAA also suggests that, with regard to Mexico, the FDA and CDC staff take into account the immigration pathways and their conditions used by immigrant workers as a factor when developing the final action plan. These migrants form the significant portion of the labor force used by U.S. food producers, packers, and food service entities. Only through a direct visit to observe the immigration process can the FDA and CDC fully appreciate the risks associated with these migration patterns and the training challenges facing the U.S. food industry. An additional potential result of the visit would also include the possibility that the CDC would understand the heterogeneity of the U.S.-Mexico border region and consider using more detailed annotations in their virus and bacteria databases to distinguish between the various border regions when possible and appropriate. The FPAA is happy to assist in the coordination of this event with the Department of Homeland Security and the relevant U.S. and Mexican Consulates.

We believe that if the above suggestions are taken into account, the resulting final action plan will be more complete, effective and meaningful.


Sincerely,

Lee Frankel
President
Fresh Produce Association of the Americas