December 20, 2006

Robert E. Brackett, Ph.D., Director United States Food & Drug Administration
Center for Food Safety and Applied Nutrition

Leanne L. Skelton Chief, United States Department of Agriculture
Agricultural Marketing Service, Fresh Products Branch Fruit & Vegetable Programs

The Association of Food & Drug Officials (AFDO) is a national organization that represents state, local and Federal food and drug safety regulatory officials. Our organization is well known for promoting uniformity and cooperation among the regulatory community, and we have actually fostered numerous collaborative projects to advance these positions. Some of the more well-known efforts we helped to start are the Seafood HACCP Alliance, States Helping States project, and the National Food Safety System (NFSS) project; and some of the model codes we have developed include the Model Consumer Commodity Salvage Code, Guidelines for Exempt Slaughter and Processing Operations and the Guidelines Cured, Salted, & Smoked Fish Establishments GMPs. As we represent state food safety program managers, we have a unique strength and impact on advancing food safety projects we believe are necessary and which are best addressed through integrated efforts of government at all levels. AFDO believes there is a current concern we both share, which needs to be addressed.

Recent outbreaks associated with fresh fruits and vegetables have been investigated by many of our members, and following each outbreak the question of the existence and prominence of Good Agricultural Practices (GAPs) programs at the grower and packer levels arises. Consumer groups, as you know, believe GAP programs should be mandated, and as more and more of these outbreaks occur, it becomes difficult to challenge their position. Although to date AFDO has not endorsed any mandated system, we do believe that it is time to strongly consider development of appropriate standards in the form of a model code for adoption by state and local regulatory bodies. Industry, in a renewed emphasis for food safety at the grower and packer level is now seeking leadership by regulatory officials. In fact, at a recent meeting of the nation’s leading tomato growers, AFDO was asked to assist in developing uniform regulations adopting specific GAPs and Best Management Practices (BMPs) for their industry. A national standard GAP certification program, auditing system and model code must be available for adoption and implementation as soon as possible.

AFDO proposes the formation of an alliance or working group comprised of government, industry, and academia to consider the development of a model code. This group should be directed by recognized food safety experts within FDA, and include state regulatory officials, USDA, academia and industry. This group should build upon the existing strengths within FDA, USDA, states, regions and industry – such as the USDA/GAPs program, FDA’s “Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables”, the North America Tomato Trade Working Group’s “Commodity Specific Food Safety Guidelines for Fresh Tomatoes” (ed.1.0); and the Florida tomato growers’ recently developed “Tomato Good Agricultural Practices and Best Management Practices.”

We recommend that state officials representing AFDO and the Associations of Fruit and Vegetable Inspection and Standardization Agencies (AFVISA) be a part of any alliance or workgroup. A national program endorsed by these government organizations is, in our opinion, crucial. We look forward to hearing from you on this matter in the hope that we can continue to discuss this proposal. As always, funding may be an issue, and will need to be addressed.

Thank you for your consideration.

Charlene Bruce, President

Joseph Corby, Director of Public Policy