Though the deadline for comments has been extended into early January, is instructive to see what industry leaders are saying about the FDA’s draft commodity specific guidance for melons, tomatoes and leafy greens.     Follow these links for comments about the draft guidance for tomatoes:

Here are excerpts of comments on tomato guidance from United Fresh and David Gombas.

Tomato Production Practices: “Refraining from use of raw animal manure”: We believe there is ample evidence that use of uncontrolled raw animal manure presents too great a food safety risk, particularly when properly composted materials, with or without animal manure, are readily available. We further believe that FDA should expressly recommend against the use of sewage sludge or biosolids as soil amendments. We suggest that this sentence be replaced with “Eliminating use of sewage sludge, biosolids, and raw or improperly composted animal manure as a soil amendment.”

Storing Cut/Sliced/Diced Tomatoes “Chilling to and maintaining tomatoes at =41°F after cutting.” o Putting tomatoes in ice water has been a common practice for firming tomatoes immediately prior to slicing. We believe that, like other immersion practices, this presents a potential for infiltration of pathogens, if present, and FDA should expressly note that the practice is not recommended.



From Laurence Jacobs and Jacobs Farm / Del Cabo comes this comment about wildlife:

As organic growers we STRONGLY OPPOSE the exclusion of wildlife from our farms. On our farms we build bird houses to attract owls, hawks, insect eating birds and bats. We also encourage frogs and snakes. Other animals use our farm(s) to access watersheds and food sources. Excluding wildlife means killing wildlife. It is also impractical. Wildlife habitat areas are important as natural filtration systems for our environment. I'm very concerned that FDA's guidelines do not consider the need to protect wildlife, the importance of wildlife on farms for rodent and insect control and the need to maintain "wild areas" to conserve natural filtration systems of water and air. Farms are a controlled and managed way to gather food. This is an activity that happens with nature not in a hospital.


From the Produce Marketing Association and Bob Whitaker:

The Background section of the draft guidance references two items about which PMA is hereby requesting more information.
In the first paragraph, FDA provides background information indicating that from 1996 to 2008, “14 produce-related outbreaks were linked to the consumption of tomatoes”. It would be beneficial for the industry and the research community to know more detail concerning these outbreaks, i.e.:

how strong was the link back to tomatoes from an epidemiological perspective;

was the original cause of the contamination determined;

were there any seasonal, geographic, product format or demographic trends identified within or between outbreaks that might be useful in formulating risk management strategies; and what did FDA learn from these outbreaks and the subsequent

epidemiological and traceback activities that might help the industry better manage food safety risks and assist FDA (and CDC) identify causative products or conditions in future outbreaks?

In the fourth paragraph, FDA describes the 2007 Tomato Safety Initiative and states: “Findings [from the Tomato Safety Initiative] will also be incorporated into future editions of this guidance, as appropriate”. From PMA’s perspective, FDA’s ongoing Tomato Safety Initiative has proven to be a successful opportunity for exchange of information between the tomato industry, FDA and state public health agencies. We urge FDA to include key, illustrative learnings from the Initiative in this version of the guidance
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TK: From what I could tell and from remarks within the submissions to FDA,  the industry presented unified comments on the FDA's draft guidance. What will be interesting to watch will be the positions of various consumer groups about these food safety draft guidance documents. It is obvious that indeed there will be some differences in perspective and approach from the organic community.