2007N-0051
  

  
Safety of Fresh Produce; Public Hearings
  


  

  

  


  

  
FDA Comment Number : 
  

  
EC7
  



  

  
Submitter : 
  

  
Ms. Deborah Wechsler
  

  
Date & Time: 
  

  
05/15/2007 11:05:09
  



  

  
Organization : 
  

  
North American Bramble Growers Association
  



  

  
Category : 
  

  
Other Organization
  



  

  
Issue Areas/Comments 
  


  

  


  

  
GENERAL
  


  

  



  

  
GENERAL
  


  

  



  

  
 The North American Bramble Growers Association is the membership organization of commercial raspberry and blackberry growers in the United States and Canada. Most of our member growers sell a large proportion of their crop directly to the public, either as pick-your-own or through retail stands on or off the farm. Some wholesale locally, but only a few are major wholesale producers. 



We recognize that small growers have a responsibility to maintain food safety standards and that serious incidents occurring on small farms can affect the whole industry, though because smaller farms produce less fruit, they put fewer people at risk. We have been working to educate our members about food safety concerns and GAPs, but have a number of concerns, especially relating to potential federal regulation and its effects on smaller producers:



1. Current GAPs and audit materials are oriented toward larger producers and confusing, impenetrable, and often irrelevant to small growers. GAPs recommendations need to address the scale and resources of small growers. Resources need to be devoted to making these materials more accessible to growers.



2. PYO and on-farm retail represent very different conditions from large wholesale operations. Customers are not as manageable as employees, and the role and responsibility of consumers in spreading illness must be addressed without scaring these consumers away from the farm.



3. Recommendations -- and any future regulations -- need to be commodity specific. Raspberries and blackberries are different from lettuce and spinach and also from blueberries, strawberries, and tree fruit in their production methods and specific food safety risks. 



4. Recommendations -- and any future regulations -- need to take into account farm size and economics. Mandatory standards and programs oriented toward large producers but enforced at the same level among smaller producers may drive many of these smaller producers out of business through their cost and management burden. The benefit in food safety may be less than the cost in loss of farms, loss of fresh, locally produced food, and loss of community access to the farm experience. 



We appreciate the FDAs concern over produce safety and hope we will all be able to work together so that our country's farmers will be supported and everyone's food will be safe, nutritious, and affordable.