Food safety has been on many minds recently as beef, chicken, Honduran cantaloupe, and various other food products have been recalled from the market. According to the U.S. Food and Drug Administration, 20 to 25 percent of the U.S. population is at high risk for food-borne illness. Both consumers and producers are more aware than ever of the vulnerabilities that exist when it comes to food due to changes in the global food supply, the introduction of new food-borne pathogens over the years, and the increasing variety of foods available to consumers.

One of our priorities at the U.S. Apple Association is to work with federal regulatory agencies to assure that appropriate, science-based, food-safety measures are in place to avoid food-safety problems. While the Centers for Disease Control and Prevention report that 14 percent of all food-borne illnesses are associated with fresh produce, only a handful of the hundreds of existing produce commodities have been known to cause outbreaks. Apples are not considered to be one of those commodities. For the vast majority of the produce industry, including the apple industry, the current FDA Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables is adequate in preventing food-borne illness.

Growers can use the FDA guide to tailor their food-safety practices to their production practices according to potential risk. This guidance is also easily updated to reflect new information or research results. Maintaining a safe supply of apples and apple products is a collaborative effort that involves all facets of the industry, from the grower, to the packer, shipper, processor, and retailer. It’s a commitment we each have to make to maintain consumer confidence.

In 2007, the FDA developed a comprehensive Food Protection Plan that recommends additional action steps for the produce industry, across the board. USApple does not believe it is necessary to impose additional mandatory good agricultural practices on the entire produce industry, only those that have increased risks.


Under FDA’s current approach, the agency monitors for outbreaks and then works with specific industries to develop practices to minimize or eliminate contamination. When outbreaks demonstrate that current food-safety practices are insufficient, FDA should advise the industry that stricter food-safety practices are necessary. In cases where industries fail to respond to FDA recommendations following repeated outbreaks, the agency should move to mandate stricter practices for that specific industry.

USApple favors this approach over mandatory food-safety practices for all produce industries because the absence of outbreaks in the majority of produce commodities demonstrates that current practices are sufficient. This approach allows different produce industries flexibility to incorporate meaningful food-safety practices while maintaining the competitiveness of U.S. producers. A mandatory approach applied across the board to all produce commodities would create a significant regulatory burden for producers, but fail to deliver a meaningful food-safety benefit.

USApple supports FDA’s current guidance approach, and believes food-safety practices should be risk-based and reflect sound science to help ensure consumers are provided healthy and nutritious apples and other produce items. Continued consumer confidence is a cornerstone for our industry.