From the federal docket on preventive food safety controls for fresh produce, part one of a lengthy  comment submitted by Lance Jungmeyer and the Fresh Produce Association of the Americas.

July 22, 2010

As an association of U.S. importers, the FPAA is uniquely situated to observe both weaknesses and opportunities for improving FDA’s imported food safety and security program. Every single shipment of fresh produce that enters the U.S. submits information to the FDA for review and possible additional examination. The FPAA is committed to finding solutions that satisfy the laudable public interest of the FDA and other government agencies to protect consumers and the industry’s interests to provide high quality, safe and secure fresh produce to U.S. consumers.

The members of the FPAA strongly support a risk-based approach that has equal oversight of both domestic and imported produce and equal oversight of small, medium, and large farms, as the most effective approach to enhancing food safety. Sound science and proper allocation of resources based on risk must be the foundation of food safety regulations moving forward. In addition, the industry strongly urges the FDA to continue  forward with additional research that would improve testing and detection methods and that would identify new procedures in growing, packing, and harvesting that could enhance food safety.

WATERMELONS

The FPAA supports comments submitted by both the National Watermelon Association and the National Watermelon Board concerning the removal of watermelons from the “melon” category. The focus on a scientific, risk-based approach would dictate that watermelons are treated as their own category when developing commodity specific guidelines for commodities targeted by FDA for their risk profile. By designating certain commodities with different risk profiles than other commodities, the FDA is highlighting the expectation that some commodities will be checked with more vigor than others.

If watermelons remain in the melon category and yet FDA is not testing watermelons as frequently as other items in the melon category, that will raise accountability concerns within Congress as they review the efficacy of new food safety regulations. Additionally, if FDA is testing watermelons at the same rate as commodities determined higher risk, then FDA will be using limited resources that could be better focused on other commodities or on other initiatives to improve food safety.

Watermelon and melon are not the same fruit. While both are in the Cucurbitacea family,watermelon is genus and species Citrullus lanatus and melons are in the Cucumis genus. Genome projects for cucurbits include watermelon, melon, pumpkin, and cucumber (http://www.icugi.org/).

A generalized categorization of ‘melons’ is not accurate botanically or in food safety regulations. As an example of the proper separation of commodities, Onions and Green Onions are separated into two commodities. Yet, they share more  commonalities through scientific classification than Watermelons and Melons. The only scientific classification difference between the onion commodities is Species. Watermelon and Melons differ in three areas; Tribe, Genus and Species.

The important difference between the Onion commodities is that Green Onions have a history of foodborne illness outbreaks and separated from Onions in a proper risk-based, commodity specific approach. With more differences between them, Watermelons should be separated from melons.

State of the Industry

During the winter months, Mexican fresh produce accounts for as much as 25 percent of fruit and vegetable consumption in the entire U.S., and the fresh produce industry represents one of the most critical elements to a successful food safety and security program in the country.

Of all of the Mexican-U.S. border ports of entry, the Mariposa Port of Entry (POE), which is located in the FPAA’s hometown of Nogales, AZ, is the largest by volume, transactions, and value for Mexican imported fresh produce. More than 120,000 trucks loaded with fresh produce entered Nogales from Mexico in 2009 alone. Today, the industry brings more than 4 billion pounds of vegetables and fruits, annually, across the border in Nogales so that families all over America can enjoy fresh produce all year in all seasons. This represents over $2 billion in fresh produce annually.

The FPAA can attest that many of the owners and operators of agricultural businesses in the U.S. and Mexico are committed to meeting and promoting food safety protocols for growing, harvesting and distributing fresh produce domestically and via export to the United States. Establishing and maintaining the highest standards in quality, safety, and security of fresh foods originating in Mexico is absolutely critical to success and survival of fresh produce industries as well as to the industries that support agricultural businesses.

The expansion of the fresh produce agricultural sector throughout Mexico is already responsible for the direct creation of literally hundreds of thousands of jobs for Mexican citizens. Along with this increase in the  number of employment opportunities, the wages paid for these new jobs have increased over the last several years.

FPAA believes a healthy and expanding agricultural business in Mexico is vital to advancing the health and the economic, social and nutritional vibrancy of the country. The following few examples demonstrate the indirect job creation engine represented by agricultural businesses in Mexico:

• Due to growers’ and exporters’ demands for better sanitation and hygiene in fresh produce fields and packing houses, a new industry has arisen supplying quality portable bathroom and hand and foot wash units for field and packing house use along with a need for companies to service, clean and repair these units.

• Transportation companies now pick up planting, weeding, and harvesting crews from around growing operations and transport them to the many farms where they are able to work for a good wage in a safe and secure environment.
 
• As growers and packers implement enhanced food safety and security programs -- field-by-field and hectare-by-hectare -- there has been an increasing demand for a more highly qualified, trained and educated work force to manage these programs. Employees can enter the work force and advance through on-the-job training and formal education.

• The desire to secure agricultural fields and the industry’s investments has produced an increased need to fence growing fields, creating a demand for supplies (concrete, fencing wire, barbed wire, heavy-duty fasteners, etc.) to build thousands of miles of fencing, trucking and transportation of those materials, and
human resources for labor.

• An amplified need for electronic surveillance for better security of packing, storage, cooling, and distribution centers in Mexico and the increased use of security guards have created market-driven demands for electronic and video technicians, computer specialists to develop and maintain electronic monitoring systems, and additional human resources to secure the food supply.

• Routine laboratory testing of water and fresh produce is on the rise across the industry. This further increases the need for trained microbiologists, chemists, and laboratory technicians, as well as laboratory equipment and facilities. In the fresh produce industry today seed purchase, pesticide and/or fertilizer use, seeding, transplanting, feeding, weeding, harvesting, packing, and box or bin marking, coding, tagging, transport and delivery are becoming increasingly transparent.

Each step is required to significantly improve the traceability of fresh produce throughout the entire supply chain. Ever more frequently, Mexican growers are identifying and tracking the crews, materials, chemicals, seeds, and product used during seeding, growing, and harvesting processes.

If product from one of these growers is found to be contaminated due to a problem for example with sanitation or employee hygiene or an improper application of a pesticide or fertilizer the specific contaminated lot can often be identified down to a hectare or a portion of a hectare rather than implicating an entire field, farm, or harvest.

 Increasingly, steps in the process are being documented and the data is being collected in information technology systems for analysis to further improve transparency and productivity as well as food quality, safety, and security. These advancements in the fresh produce industry in Mexico are developing at a rapid pace– and they create additional needs for information technology and database specialists, and food quality,  safety and security specialists and managers.

FPAA knows that not every farmer in the United States, Mexico, Canada and in other U.S. trading partners has adopted the kinds of food safety programs and measures that many in the industry have worked to implement. As a result, there is a significant risk that one of the growers, who may not be moving forward with the balance of the industry into higher standards, could be the source of problems that harm the entire industry, regardless of a uninvolved grower’s food safety practices. This could result in a potential economic catastrophe for many in the Mexican fresh produce industry.

For instance, over several growing seasons the U.S. Centers for Disease Control implicated cantaloupe in a series of outbreaks of salmonellosis. As a result, in 2001 FDA placed the entire Mexican cantaloupe industry on an import alert – bringing many Mexican growing operations to a halt.

When FDA was forced to explain to the U.S. press or to the U.S. Congress what had caused one particular outbreak of hepatitis-A, FDA prematurely reported that Mexican green onions were implicated. As a result, in 2003 FDA placed all green onions originating from Mexico on import alert. If a contamination scare occurred in the Mexican agricultural industry similar to what occurred in Salinas, CA in 2006 with fresh spinach – it is likely a majority of growers could not survive economically

Therefore, FPAA is actively seeking partners: in industry, in the Mexican and U.S. regulatory agencies, in Congress and in the press; to move all parties toward a more rational and dynamic risk-based import program that secures and safeguards the food supply, protects consumers in Mexico and the U.S., reduces unnecessary burdens on safe and secure Mexican fresh produce shipments, and empowers a more effective, efficient, and reliable regulatory regime.