2007N-0051
  

  
Safety of Fresh Produce; Public Hearings
  


  

  

  


  

  
FDA Comment Number : 
  

  
EC12
  



  

  
Submitter : 
  

  
Mr. Stan Hazan
  

  
Date & Time: 
  

  
06/06/2007 07:06:52
  



  

  
Organization : 
  

  
NSF International
  



  

  
Category : 
  

  
International Organization
  



  

  
Issue Areas/Comments 
  


  

  


  

  
GENERAL
  


  

  



  

  
GENERAL
  


  

  



  

  
 Re: Public Hearings on Safety of Fresh Produce, April 13, 2007, College Park, MD

DEPARTMENT OF HEALTH AND HUMAN SERVICES

  Food and Drug Administration

  [Docket No. 2007N-0051]



Dear Sir/Madam:



This letter recommends that the FDA support the development and implementation of a U.S. national consensus standard (NSF/ANSI Standard for Fresh Produce) as a way to simplify and optimize compliance with federal regulations.



NSF International (NSF) is an independent, not-for-profit developer of consensus national standards, and provides accredited third-party inspection, testing and certification services, for both products, and management systems.  NSF specializes in environmental and public health, providing multiple services in the areas of food, water, and the environment since 1944.  NSF is also a WHO Collaborating Center for Food Safety and Water Quality.  In the food sector, NSF provides conformity assessments services to growers, processors, manufacturers, distributors, and retailers of food, food equipment, food service, food retail, and more.  NSF understands the importance of food safety throughout the entire supply chain.



A key element to providing a high level of confidence in the supply chain is to ensure that risks are being managed appropriately.  That involves developing, implementing and verifying valid HACCP plans, as well as GMPs, and independent verification that the prescribed practices are being carried out and documented.  A significant challenge for regulators and industry is understanding the multitude of regulatory requirements and industry specifications with which a grower, processor, distributor must comply.  It appears that every food industry group is developing its own set of requirements, systems, specifications etc.  This causes significant confusion in the supply chain and creates opportunities for errors.   



We believe that a U.S. National Standard is required for fresh produce that would standardize and simplify the requirements that any company would have to comply with.  Accredited third party certification systems could independently verify conformity to the national standard.



The U.S. national standard would be developed using the ANSI standards development process, which provides for input by all stakeholders, to ensure the finished standard is acceptable and usable by all.   The standard would address all federal regulations, and consider state and local regulations in its development.  The standard would also consider the items important to industry and as users as well.  Ultimately, the consensus standard is ratified by the NSF Council of Public Health Consultants, an industry-free group of academic and regulatory public health professionals.



The benefits of developing, adopting, and utilizing a U.S. national standard for fresh produce is that it greatly simplifies the requirements for all parties, thereby increasing participation and compliance.  The consensus standard is always open to revision as new information is brought forward,

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  








  

  
 or as new regulations are promulgated.  This national consensus standards system has worked very well in existing NSF programs, as well as countless other industries that face similar issues of hazardous products in the occupational or consumer environment.



NSF International recommends that the FDA consider supporting the development of the NSF/ANSI Standard for Fresh Produce. 



Stan Hazan, NSF International, 734-769-5105

hazan@nsf.org