Good Point - Save “Lassie”
Food safety rules for tree fruits need to reflect real risks and economic realities.
In late March, Elizabeth Taylor died at age 79 after a long career in front of wedding cakes and movie cameras. Her first major Hollywood picture was Lassie Come Home in 1943. This film was the forerunner to the Lassie television show of the 1950s and 60s: there the featured dog, a Rough Collie, was always a steady companion to Timmy, a boy living in an ideal, rural America.
Almost every orchardist has a farm dog. They provide close companionship when their masters are at their often lonely and isolated work. As pets, they bring enjoyment to all members of the farm family. They give warning of approaching strangers or cars. They playfully ride shotgun in many a pickup truck.
“Lassie” is not a food safety risk in orchards.
This is a message the Northwest Horticultural Council is in the midst of conveying to federal food safety regulators. As a result of the enactment on January 4, 2011, of the “FDA Food Safety Modernization Act,” our tree fruit industry is preparing a comprehensive response to anticipated action by the U.S. Food and Drug Administration on fresh produce safety standards.
By the end of this year, FDA is required by the new law to publish a notice of proposed rulemaking “to establish science-based minimum standards for the safe production and harvesting of …fruits and vegetables…” Areas to be covered include soil amendments, hygiene, packaging, temperature controls, animals in the growing area, and water. As directed by Congress, high-risk produce items are to receive the most attention by the government’s regulators.
While certain small farms are exempt under this law, it is unlikely the so-called “Tester Amendment” will be of real benefit to many, if any, commercial growers of tree fruits in the Pacific Northwest.
Industry task force
A special task force of industry food safety experts has been assembled by the Northwest Horticultural Council and is giving advice to our office on the development of a set of Good Agricultural Practices (GAPs) designed for our low-risk tree fruits. The aim is to address any real risks to an ultimate consumer’s safety, but only those risks. And addressed in a way that takes into account economic reality. For example, the cost of laboratory testing needs to be seriously considered before suggesting that an orchardist be forced to spend money on any regular regime of testing for human pathogens in irrigation water.
We hope to have a draft GAP standard that eventually will be accepted by other similar fruit-growing regions within the United States. One that will cover all deciduous tree fruits, as opposed to separate standards for each variety: we do not want or need three separate food safety plans for the growers of apples, pears, and cherries. Our present goal is to have such a GAP document in good shape by later this summer and ready to be submitted to FDA when events warrant.
Again, our focus is on the Food and Drug Administration. This is the federal agency that is empowered to write public food safety regulations governing the actions of growers and packers. Any final regulations issued by it will have the force of law.
Meanwhile, private food safety schemes abound: most prominent now in our tree fruit industry are GlobalGAP and Safe Quality Food (SQF). These two are unlikely to go away soon as at least a few of the major retail grocery chains who currently demand supplier compliance with these now entrenched private schemes are not likely to abandon them, even should FDA issue new public food safety standards for produce.
Harmonizing food safety programs
Efforts are under way in the nation’s produce industry, led by the United Fresh Produce Association, to harmonize all the many existing private schemes’ various food safety provisions. The aim is to boil things down to one set of food safety provisions—regardless of private scheme—thereby reducing the number of costly and duplicative audits now suffered by commercial fresh fruit and vegetable growers and packers. The fact is that the existing private food safety schemes cover almost the same food safety ground, with slightly different wording. They do differ in their coverage—or noncoverage—of social and environmental issues. While some food safety aspects of these schemes are valid, other aspects are unreasonable. Especially when the very real differences between risk factors posed by individual commodities are not taken into proper account.
An example of reasonableness lies with the issue of animal exclusion. It is reasonable for warehouses and packing sheds to have a policy in place to prevent wild or domestic animals entering buildings where food is processed or stored. And, it is reasonable for a grower of a ground crop, such as one of the mechanically-harvested leafy greens, to try to prevent animals from roaming across open fields near harvest time.
Given the threat of E. coli 0157:H7, it may well be reasonable for there to be a rule against having a herd of sheep or cattle graze on the grass on the floor of an orchard. But it is not reasonable for an orchardist to be forced to worry about the incidental activity of common wild or domesticated animals.
And it is certainly unreasonable to execute or exile every orchardist’s “Lassie.”
Elizabeth Taylor lived a long and interesting life—maybe because she started out with a good dog, “Lassie,” at her side.