Today we feature another in a series of industry submissions to the FDA docket on preventive controls for produce safety. This letter is from Laura Phelps and the American Mushroom Institute on their well-developed safety program and the benefits of using existing USDA marketing and promotion orders in food safety efforts.

From AMI:


June 8, 2010

Dockets Management Branch (HFA-305)
Food and Drug Administration
5630 Fishers Lane
Rockville, MD  20852

RE:   Docket No. FDA-2010-N-0085

Dear Sir or Madam:

Thank you for the opportunity to provide comments in response to the February 23, 2010 Federal Register Notice regarding Preventative Controls for Fresh Produce.  The American Mushroom Institute is the national trade association that represents domestic mushroom growers, processors, packers, and allied service providers. 

As presented at the FDA Listening Session in Harrisburg, PA on May 6, 2010, the mushroom industry has a remarkable success story to tell – mushroom growers and shippers have truly been proactive in their food safety efforts.  The mushroom industry has the only nationwide, commodity specific, USDA audited good agricultural practices program.  In less than 18 months since the USDA checklist was finalized, farms representing the majority of US production have successfully passed a MGAP audit conducted by USDA or other third party auditor.  And now in recognition of the changing regulatory climate and customer driven demands, the industry is positioning itself to have a national certification and verification program for all growers and packers.

Our efforts can provide a model for the development of a commodity specific Good Agricultural Practices program and strategies to enhance compliance.   In 1999, Dr. Luke LaBorde at Penn State University, in conjunction with AMI, offered a Mushroom HACCP Workshop – “Managing Risks to Ensure Safe Food Supplies.”  The workshop incorporated a set of guidelines for identification and control of potential food safety hazards.  This evolved into an AMI/Penn State document in 2000 entitled “Good Management Practices for Safe Growing, Harvesting and Packing of Fresh Mushrooms,” based on the FDA’s Good Manufacturing Practices, the “Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables” and Codex standards.

In 2005, Dr. LaBorde and AMI members further expanded this into a complete food safety program – “Guidelines for Developing a Mushroom Good Agricultural Practices Program – Compost Preparation to Product Shipping” which detailed the standards of a mushroom specific, good agricultural practices program  and became known as MGAP.

In 2007, growers redoubled their efforts.  As packinghouse audits increased, customers and auditors began asking about the growing operations.  What became very clear was that auditing a mushroom farm was very different from a lettuce field, an apple orchard or even a tomato greenhouse.  We saw our chance to have audits tailored to the unique characteristics of mushroom production which would make more sense and better serve our customers.

Representatives of farms and packing houses from across the United States, along with food safety consultants and Penn State faculty, collaborated to develop a comprehensive food safety initiative, based on the MGAP program.  The 2005 MGAP was compared to and harmonized with current third party audit requirements, industry practices were factored in and an industry-wide, agreed upon set of good agricultural practices was adopted.

The most significant key to success was the education and training program. Merely handing over a set of rules to a grower and saying “do this” is not an effective game plan.  Tools for understanding, implementation and compliance are essential.

First, a Food Safety Training Kit was developed, along with Train the Trainer sessions to facilitate its use on the farm.  Any food safety plan must include employee training – hand washing, good hygiene practices, recognition and disposal of contaminated product, to name just a few components.  Everything the grower needs to train his employees is included in the Kit.

We also developed an audit based on the MGAP standards since part of the strategy for implementation which was to “teach to the test.” Growers could conduct a self-audit to gauge their progress and identify areas that needed attention.

The next item to tackle was the documentation required for an audit. Growers are doing most of the things required in a food safety plan, they just aren’t writing them down to provide evidence to an auditor.  We felt it was much more important to give growers the templates for checklists, forms, logs, schedules, examples of Standard Operating Procedures, and let them modify them for their own operation than spend their time designing their own.  Signs need to be posted – we designed and printed the signs and provide them to growers.   These materials are available at our websites: www.mgap.org and http://www.americanmushroom.org/bestpractices

All components of the program were tested on a small farm with a typical operation not only to make sure they were applicable but also to provide a teaching tool for the grower training sessions.
Finally, we held a series of training sessions, again following the “teach to the test” strategy – giving each participant a manual divided into the 14 food safety areas, with the standards, the guidelines, the samples of documentation required, and the audit checklist arranged section by section.  A copy of the manual is attached.  Our philosophy is to keep it simple, make it practical, make it doable.  Create the tools, test them and then teach them.

A few key points:   For our workforce, every document is printed in English and Spanish.  We hold two sets of training sessions – one in English, one in Spanish.  We give certificates for every training session we hold – people like to get recognition and credit for their efforts and auditors like to see documentation.  Research must back up food safety requirements.  For an industry that uses composted animal by-products, this has been key.

We have the benefit of a small and cohesive industry, with both a strong trade association and a federally authorized research and promotion program which facilitates communication and cooperation.  But the credit for this success goes to the commitment of our growers and packers – it starts with owners and goes throughout the entire workforce.  The process never ends, from updating the Standards to reinforcing good hygiene practices with harvesters.

AMI believes that the size of a farm or its method of production does not negate the need for a strong food safety program.  In mushroom production, safe water, clean hands, sanitary facilities, an uncontaminated growing environment and common sense should be principles on every farm that is offering what it grows to a consumer.  Scale appropriate means larger farms have more wells to test, not that smaller farms are exempt from testing. The MGAP program is just as applicable on a certified organic farm as it is on one with conventional production.

The proposed rule should not only allow, but encourage, the use of existing organizational structures at USDA, such as marketing orders, marketing agreements, and research and promotion orders as mechanisms through which safety standards for fresh produce could be implemented.

Finally, we urge USDA and FDA to dedicate resources for worker training.  A huge amount of work has been done independently by grower organizations, land grant universities and extension agents.  It would be very beneficial to bring these people together, let them share their experience and learn from each other’s successes and mistakes. We all have a responsibility to provide the tools that growers, supervisors, pickers and harvesters need to help them comply with the rules that are coming, but more importantly, to provide a safer food product to consumers.

Thank you for the opportunity to provide these comments.  Please call on us at any time for clarification or additional information.

Sincerely,
                     
Laura Phelps
President