Agriculture Reference
In-Depth Information
produce only for controlling quarantine pests (e.g., irradiating mangoes for fruit fl y).
In 2008, the FDA approved irradiation of leafy greens to reduce microbial contamina-
tion, which may provide an alternative strategy for this segment of the produce indus-
try. The FDA does not have a process standard, but the produce and buying industries
are developing process standards.
In 1998, the FDA published voluntary guidelines, GAPs, to help growers, both
domestic and foreign, reduce the risk of microbial contamination at the farm level.
The FDA specifi ed particular areas of risk (water, manure, and municipal biosolids,
worker health and hygiene, sanitary facilities, fi eld sanitation, packinghouse sanita-
tion, transportation, and traceback) that should be addressed but did not specify par-
ticular production practices. GAPs are guidance, not a process standard. This was a
general, common-sense guide, because, at that time, there was very little specifi c
research to provide more concrete advice.
Over time, there has been a push to develop more specifi c guidelines. In 2004, the
FDA and the Centers for Disease Control and Prevention (CDC) met with produce
industry leaders to discuss numerous foodborne illness outbreaks associated with
produce. At that meeting, industry representatives agreed to take the lead on develop-
ing commodity-specifi c GAPs that would provide additional guidelines tailored to
individual commodities that had been implicated in recent foodborne illness
outbreaks.
After the 2006 outbreak linked to spinach, the California leafy greens industry
developed a set of Best Practices (also known as
the metrics
) that would become the
standard for the LGMA. This is a process standard required for all participants and
verifi ed with mandatory audits; it is not guidance. Unlike the FDA's initial guidance
document and the commodity-specifi c GAPs, the new Best Practices defi nes practices
with specifi c criteria and target values for controls and monitoring. As an example,
the original GAPs document warned farmers that “water quality should be adequate
for its intended use.” At the time, the FDA was justifi ably reluctant to specify what
adequate water quality was because it did not have enough data to support specifi c
thresholds. The new Best Practices are much more specifi c, but the science is still
relatively weak. For example, the standards for well water require testing before pro-
duction begins and monthly testing during the production season. The document
recommends specifi c tests for measuring levels of generic
E. coli
in the water and an
action plan to be applied if counts reach certain numerical thresholds. However, the
effectiveness of these practices under different growing conditions as well as the costs
are not well understood.
There have been some industry and consumer calls for the FDA to step in with
mandatory process standards. Although the FDA does not currently have food safety
process standards with respect to microbial contamination for the fresh produce indus-
try, it could impose mandatory food safety standards if deemed necessary. However,
developing process standards without adequate scientifi c support could undermine
public confi dence in food safety regulators if another outbreak occurred. The FDA has
imposed mandatory standards on fruit juice. In the late 1990s there were three food-
borne illness outbreaks associated with unpasteurized fruit juice. In 1998, the FDA
published a rule requiring juice processors to use Hazard Analysis and Critical Control
Point (HACCP) principles to reduce risk. Processors are required to use processes that
