← Northwest Horticultural Council
AMSNonrulemakingAMS-TM-21-0034

Supply Chains for the Production of Agricultural Commodities and Food Products

RIN
—
Last modified
Dec 6, 2024
Comment window
closed 1863d ago
Northwest Horticultural Council filings
1

Activity

Northwest Horticultural Council filed 1 comment on this docket between Jun 22, 2021 and Jun 22, 2021. 136 other organizations filed here. The comment window closed 1863d ago.

What Northwest Horticultural Council filed (1)

Jun 22, 2021· Comment from Northwest Horticultural Council· AMS-TM-21-0034-0786

The Northwest Horticultural Council (NHC) represents the growers, packers, and shippers of apples, pears, and cherries in Idaho, Oregon, and Washington on federal and international policy and regulatory issues. Below is a summary of our comments in response to Docket Number AMS-TM-21-0034. From crop inputs to retail packaging, the supply chain for the tree fruit industry is substantial and complex. For the purposes of these comments, the NHC will focus on three aspects of the supply chain where industry has faced disruptions in the past year: workforce, sanitation, and transportation. Our full comments are enclosed. Workforce Needs From growing to packing, the production of tree fruit is a labor-intensive endeavor. The current agricultural workforce in the Pacific Northwest is aging, and few new domestic workers are entering the field. This has forced growers to increasingly rely on the H-2A program to bring in the workers needed to grow and harvest the crop. Tasks associated with the growing and harvesting of tree fruit are very time sensitive. Therefore, it is critical that the H-2A program be implemented in a manner that allows workers to arrive on-time. This involves the work of a number of agencies, including the U.S. Department of Labor and the U.S. Department of Homeland Security. It also must be noted that growers pay a high price for participation in the H-2A program. The costs of this program – in particular the wage rates – continue to escalate at a rate that far outpaces what is justified by economic conditions, and is quickly making the program unaffordable to a larger number of growers. Reform of how both the Adverse Effect Wage Rate and state prevailing rates are set so that they better reflect real-world conditions is necessary to ensure that this program is a viable option for growers now and into the future. Enclosed is a copy of the comments provided by the NHC in response to DOL's proposed rule entitled "Temporary Agricultural Employment of H-2A Nonimmigrants in the United States," published in the U.S. Federal Register in 2019, regarding ways to make the H-2A program more accessible to growers. This rule has not yet been finalized. Sanitation Supplies Beyond the COVID-19 pandemic, the tree fruit industry has and will continue to be in need of supplies to clean and sanitize food contact surfaces in both the orchard and packinghouse in order to prevent cross-contamination of naturally occurring pathogens of human health concern. This includes personal protective equipment for workers, chemicals to kill food-borne pathogens, and equipment to administer these products. Maintaining an adequate national supply of these products – and providing high priority access to the food industry when shortages exist – is critical to maintaining a safe food supply. Transportation In recent months, shortages have developed in two key areas that are impacting the ability to transport tree fruit. First, the industry is facing a pallet shortage so severe that this critical transport component has been unavailable for purchase in some cases – forcing companies to get creative to prevent disruptions. When pallets have been available, prices are more than double what they had been previously. We are concerned that the impacts on tree fruit growers, packers, and shippers will be even more significant this fall once apple and pear harvest begin if the situation does not change. Second, reduced access to ocean shipping containers has hindered the ability to ship tree fruit to overseas markets. The Pacific Northwest tree fruit industry exports roughly one-third of the apples, pears, and cherries produced. With the exception of Canada and Mexico, the majority of this fruit is shipped to Asia through the ports of Seattle and Tacoma. Our shippers rely on tree fruit serving as "return cargo" in the otherwise empty containers returning to China via other Asian countries. Unfortunately, beca…

View on regulations.gov →

Abstract

No abstract recorded.

View on regulations.gov →

Co-filers (136)

See everyone who commented →
Supply Chains for the Production of Agricultural Commodities and Food Products (AMS) — Northwest Horticultural Council | OpenPolis