Seeing is believing. That’s why conducting field tours of farms and packinghouses with senior U.S. Food and Drug Administration (FDA) policymakers and regulators is a fantastic way to inform them about challenges facing the fresh produce supply chain. Bearing witness to produce operations in action and hearing directly from industry members better equips officials to develop regulations that reflect real-world workable solutions to our industry’s unique food safety needs. Facilitating connections between FDA and industry members—such as through the field visits PMA staff recently helped arrange in California and Delaware—has been an important aspect of our Issues Leadership work on the Food Safety Modernization Act (FSMA).
Turns out such first-hand experiences are as valuable to FDA as they are to the fresh produce industry. Reflecting on these recent field visits in his FDA Voice blog post, Dr. Stephen Ostroff, FDA’s deputy commissioner for foods and veterinary medicine, wrote: “Produce farms have not been regulated like this before—it’s new territory for both the farming community and for FDA. We were asked many questions and received a great deal of feedback about the new regulations. But we found a strong commitment to providing consumers with safe fruits and vegetables and to moving forward in a collaborative fashion. For our part, I think it’s incumbent on FDA to protect public health without requiring a lot of unnecessary steps or measures that don’t achieve that goal.”
We couldn’t agree more. Produce safety is paramount and collaboration is imperative to striving toward that goal—and to ensuring FSMA regulations are practical for our industry. PMA’s continued work with the National Association for State Departments of Agriculture (NASDA) further speaks to this point. To plan these field tours with FDA senior leadership, we partnered with NASDA, along with the California Department of Agriculture and Delaware Department of Agriculture. State agencies have the best understanding of the specific growing and harvesting practices in their areas. Plus, many state agencies have long-standing relationships with produce growers as well as state and local produce associations.
State government agencies will play a significant role in FSMA rule implementation and compliance verification. As a result, PMA has advocated strongly on behalf of state agencies to assume the FSMA education, compliance and enforcement roles. We applauded the FDA back in September when it awarded $21.8 million in cooperative agreement funds to 42 states to help implement the FSMA Produce Safety Rule. These funds will be used by states to develop and provide education, outreach and technical assistance, and develop programs to address the specific and unique needs of the growers in their farming communities. (Speaking of assistance, PMA has compiled a FSMA training calendar that connects members with ongoing training courses they need for the Produce Safety Rule and the Preventive Controls for Human Foods, as well as sprout-specific training through the Sprout Safety Alliance.)
Whether field tours or other face-to-face talks that have taken place throughout the FSMA rule making process, stakeholder meetings allow FDA officials and state officials to understand and hear directly from produce business owner/operators about FSMA implementation challenges and current produce safety programs. Communication and collaboration is crucial to effective implementation of FSMA.
And as we see from Dr. Ostroff’s reaction, these efforts pay dividends—not only at helping those who regulate our industry understand the realities and experiences of fruit and vegetable producers, but also in demonstrating the produce industry’s commitment to food safety and our industry’s inherent nature to lead by example.
“These trips also highlighted the fact that that many food producers and industry associations have already invested a lot of time and effort in food safety measures,” Dr. Ostroff wrote. “In some instances, what they have put in place goes beyond what is required under FSMA. In both trips, we saw farmers, other food producers, and industry associations stepping up to address past safety issues, including by developing their own on-farm standards and implementing audits to verify that those standards are met. Some developed treatment protocols and funded research to fill data gaps. These efforts will make it much easier to meet the new federal standards.”