Support for regulations with flexibility that allow fruit and vegetable growers to manage risks unique to their production environment as well as calls for a final rule were among the key messages delivered by the International Fresh Produce Association’s food safety and regulatory team during the U.S. Food and Drug Administration’s recent virtual public meetings on proposed changes to agricultural water requirements in the produce safety rule.
During the February 14 meeting, Dr. Emily Griep, IFPA vice-president of regulatory compliance & global food safety standards noted that ensuring the microbial quality of water used to grow, harvest and pack fruits and vegetables is a complex component of food production.
“We commend FDA for proposing this systems-based approach that not only allows, but expects, growers to account for changes in our understanding of science, testing, and risk mitigations,” Dr. Griep said. “It’s critical that the rule be able to accommodate the very different water sources, uses and types of risks specific to a grower and region.”
“Many produce growers already test their water to satisfy third-party audit requirements, and we don’t expect this to stop. We suggest growers be allowed to leverage historical testing data that provide insight to their water system, but we also believe that testing for generic E. coli, which FDA proposes as a default, is limiting in some situations, and that the rule, as currently written, ostensibly restricts growers from using more appropriate methods and analytes due to the lack of clarity in how to establish that an alternate method is ‘scientifically valid.’”
IFPA’s testimony also addressed the need for FDA to continue working closely with stakeholders as additional guidance and resources are developed.
During the February 25 meeting, IFPA was represented by chief food safety & regulatory officer Dr. Jennifer McEntire on a panel discussion of the provisions, while director of food safety & quality Gretchen Wall offered additional testimony.
Dr. McEntire urged rapid review of comments and FDA finalization of the rule. “Industry and academia need to continue building the knowledge base for water assessments, implement mitigations, and start the education process,” she said. She also acknowledged that the current proposal is much more protective of public health, calling the holistic, systems approach to agricultural water “revolutionary” compared to the rest of the Produce Safety Rule.
“Knowledge of how to conduct a risk assessment is needed to determine the real impact (severity) of a hazard,” said Wall.
Wall’s testimony reinforced the need for FDA to reconsider the proposed provisions which allow microbial die-off without corresponding data for appropriate decision-making. The use of a pre-harvest application interval as a mitigation/corrective measure may be appropriate in certain circumstances, but only with support from a robust risk assessment and relevant supporting scientific data.