PMA Comments Provide Real-World Industry Input On FDA Guidance

Newark, Del. Produce Marketing Association (PMA) filed comments today with the Food and Drug Administration (FDA) as part of the associations ongoing work to bring industry experience to the national discussion of how to better safeguard leafy greens, tomatoes and melons. PMAs comments were filed in response to draft guidance for each of those commodities that was recently proposed by FDA; the comments reflect both industry input and the expertise of PMAs food safety and regulatory experts.

In addition to providing input specific to each of the draft commodity guidance documents, PMA raised several common issues or requests with the agency. For example, the association urged FDA to add content to all three documents to emphasize the importance of risk assessment and risk management and highlight the responsibility of everyone in the supply chain to perform these assessments. PMA also recognized some of the information gaps facing FDA and the industry, including a lack of information regarding risk factors for water used for irrigation and pesticide mixing, and lack of validation of composting processes. The association urged FDA to partner with the Center for Produce Safety (CPS) at the University of California at Davis and other funding agencies to research answers to these and other produce-specific food safety questions. CPS was founded in 2007 by PMA and Taylor Farms to identify, prioritize and fund produce-specific research. As of September, CPS has issued $4.2 million in research grants to covering 24 projects.

Within the context of these draft guidance documents, PMA also supported FDAs desire to include traceback into basic food safety programs and offered the Produce Traceability Initiative (PTI) as an industry model to be considered by the agency.

Our comments were developed with the assistance of broad industry input encompassing many years of real-world experience said PMA Chief Science Officer Bob Whitaker, Ph.D., the primary author of PMAs comments. It helped that FDA based much of its draft guidance on practices that have been implemented in the field and documented by industry. We look forward to working with FDA as these guidances are completed.

Regarding the need for additional research to fill knowledge gaps, Dr. Whitaker said, CPS is a logical body to conduct produce-specific food safety research, because it already has the infrastructure and research network in place to do it efficiently and effectively.

PMA Vice President of Government Relations and Public Affairs Kathy Means reported that FDA will consider all the comments it receives on these guidance documents, revise them as needed, and then publish final guidance. She also noted that the industry can reasonably expect regulation of fresh produce safety in the future.

PMA has called on FDA to create risk- and science-based rules that apply to U.S.-grown and imported produce alike this guidance is a key step along that path, said Means. Pending food safety legislation in Congress also envisions rules for fresh produce. We dont know what those final laws will look like, but we can surmise they will require some sort of regulation of fresh produce by FDA.

Source: PMA