publication date: Aug 17, 2009
author/source: Lynn Byczynski
The Food and Drug Administration has released draft "guidances" for growing and handling tomatoes, leafy greens and melons to prevent microbial contamination. FDA says its guidance documents represent the agency's current thinking on a topic, and are not binding. However, FDA Commissioner Margaret A. Hamburg, M.D., said the guidances "will be followed within two years by enforceable standards for fresh produce."
As currently written, these documents do not exempt small or
direct-market farms and could be considered a serious threat to them if
these recommendations eventually become law. They are comprehensive to
the point of being intimidating, covering virtually every aspect of
growing, harvesting, washing, packing, transporting, and marketing
these three crops. The tomato guidance, for example, is nearly 25,000
words. (In comparison, the first Harry Potter book is about 75,000
words.) Ironically, little attention is paid to pesticide use as part
of the food safety issue; these proposals are all about preventing
microbial contamination of food.
That's not to say that these
are all wrong-headed. Many of the recommendations provide helpful ways
to think about food safety, because they attempt to cover every
conceivable way that produce can be contaminated. Most are common
sense, or things you have heard before, such as the importance of
having employees wash their hands before picking, using potable water
for irrigation and washing, not using raw manure on a leafy greens
crop, using clean harvest containers, and avoiding fields with runoff
from livestock areas. Some may be new considerations; for example, that
warm tomatoes should not be submerged in cold water, which can force
contaminants on the skin into the tomato flesh at the stem scar.
Some recommendations are more troubling. Growers are advised to
"minimize potential access by wildlife" and a section on workers
includes the suggestion that "employees, visitors, and other field
personnel wear clean and suitable outer garments. Consider, as
appropriate to the operation, using hair restraints, plastic aprons and
sleeves, restricting nail polish or false nails, and requiring empty
pockets above the waist." And there are references to sanitizing washes
(e.g. bleach) for produce that conflicts with oranic standards. There
are also significant recordkeeping recommendations, which would allow
quick traceback of any produce found to be contaminated.
kinds of recommendations seem more appropriate to a medical laboratory
than a farm field. And that is what has many people worried about the
current direction of the food safety conversation. Not only is there
the chance that they will eventually become law, many of these
recommendations are already requirements to sell to wholesalers and
grocery store chains.
As farmers, we owe it to ourselves and
our customers to do everything in our power to keep our produce safe
and clean. And we need to read and comment on these guidances before
they are finalized. Comments should be submitted before Oct. 30 to be
considered in the drafting of the final documents. Click here to go to the FDA website.