Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables; Request for Comments and for Scientific Data and Information

Dockets Management Branch (HFA-305) Food and Drug Administration 5630 Fishers Lane Rockville, MD 20852 Re: Docket No. FDA–2008–N–0455; Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables; Request for Comments and for Scientific Data and Information SUMMARY: The Food and Drug Administration (FDA) is requesting comments and scientific data and information that may assist the agency to improve the guidance to industry set forth in the ``Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables,'' issued in 1998. Specifically, FDA is seeking information about current agricultural practices and conditions used to grow, harvest, pack, cool, and transport fresh produce; risk factors for contamination of fresh produce associated with these practices; and possible measures that FDA could implement that would enhance the safety of fresh produce. Dear Sir or Madam: The following comments are offered on behalf of the National Potato Council (NPC). The NPC represents more than 95 per cent of the producers of fresh potatoes in the United States. Potato growers are committed to continuing to produce high quality fresh potatoes that safely provide a nutritious staple to the American diet. NPC and the State Organizations that work with and represent potato growers work with their members to ensure that the food safety practices that have been the standard within the industry for many years are adequate to continue the unblemished record of the potato industry in producing fresh potatoes that have not been related to any occurrence of food borne illness. In areas where improved technology, expanded recordkeeping or modified production practices provide alternatives to strengthen the food safety profile of the fresh potato the industry has moved quickly to adopt those measures. Providing fresh fruits and vegetables to consumers that provide the highest level of protection from food borne illness is best accomplished by adopting procedures and safeguards that are based on clear, science and epidemiological based assessments of risk. It is clear that based on production characteristics that vary by crop and region and consumption patterns that vary based on preparation food safety for fresh fruits and vegetables must be directly related to the varying levels of risk. The epidemiological history of the particular crop must be directly related to the recommended food safety practices. As the Federal Register Notice (FRN) requesting these comments clearly identifies of the 72 cases of food borne illness associated with fresh produce reported between 1996 and 2007 that were not related to unsafe food handling practices, none were related to the consumption of potatoes. The FDA's Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables has served and can continue to serve as a template for the potato industry to continue to refine long established industry practices that ensure the safety of fresh potatoes from consumers. The Guidelines and the application of the guidelines should always be based on the risk associated with the production, packing, distribution and consumption of an individual crop and not the broad category of fresh produce. The FRN soliciting comments clearly indicates that the investigation inspections following food borne illness indicate that efforts to improve the overall food safety performance for fresh produce should focus on some potential sources of contamination in particular. According to the results of the investigations efforts to reduce the presence of microbiological contaminants should focus on worker health and hygiene, water quality, domestic and wild animal issues, and facility and equipment sanitation. The potato industry believes that the nature of the fresh potato production process and the history of supplying fresh potatoes without a linkage to food borne illness…