It is not bedside stand reading (what is, when you come down to it?), but the United Fresh Produce Association’s comment to the FDA on the Designation of High-Risk Foods for Tracing does have several turns of phrase that reflect the intelligent and no B.S. style of David Gombas.

Check out the full comment here:

The document argues against a formalization of a “high risk” commodity list A few excerpts from the United Fresh comment:

First, “high risk” and the need for traceability are not connected. The need to trace implicated foods back to the source of contamination and forward to all other potentially contaminated foods can occur in any commodity, regardless of prior linkage to foodborne outlooks.

Second, no food is inherently “high risk.”

Third is the consequence of a “high risk” designation to public perception and confidence in the safety of the food.... Indeed the fundamental purpose of the proposed Produce Safety rule is that the produce coming from compliant operations will not be high risk. While we agree that all tomatoes should have adequate and accurate record keeping to enable traceability, designating all tomatoes as high risk will neither improve their safety nor consumer perception of their safety.

Finally, we are concerned that a list of high risk commodities has the potential to be used for purposes other than to identify foods for which additional record keeping requirements are appropriate and necessary, much in the same way that facility registration has been proposed for separating operations that are “farms” from “facilities,” or how the RFR categorizations are being proposed here. Consequently, we are even more concerned that the proposed model is deeply flawed.

Therefore we respectfully urge FDA to discontinue efforts to designate any commodities, by whatever classification systems, as inherently high risk and, instead, focus on identifying commodities for which enhanced record keeping requirements are appropriate and necessary to protect the public health, even if that results in enhanced requirements for all foods.

Should FDA disagree with our comments and proceed with a list of foods designated as high risk, we respectfully urge FDA to pilot such a list and its use before formalizing it in any regulation.


TK; The FDA is under no court-imposed deadline to come up with a solution to the “high risk” commodity/tracing equation, so the agency may take its time to finalize their approach. Ironically, the way to make the produce industry least unhappy may be to designate all fruits and vegetables as high risk.


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