In its comments, PMA encouraged the FDA to state explicitly that the draft guidance "is intended for all fresh-cut processing firms" rather than the current more inclusive statement that could be interpreted to include purchasers of fresh-cut produce, such as wholesalers, distributors, retailers, or foodservice operators.
PMA also urged that a paragraph be added that clearly distinguishes what types of companies are covered within the scope of this guidance by informing the user that the document applies to processors only and not to their customers such as wholesalers, distributors, retailers, or foodservice operators.
FDA had issued the draft guidance earlier this year and invited public comment. Citing increases in foodborne illness linked to fresh produce, the agency created a Produce Safety Action Plan in 2004, and fresh-cut safety guidance was listed as one of the priorities in the plan. In addition, FDA identified this guidance as one of its 2006 priority items.
"Without these clarifications, we're concerned that some people, including health inspectors, might mistakenly seek to enforce guidance about storage, transportation, product rotation, and record-keeping on companies other than processors," Kathy Means, PMA vice president of government relations, said.
PMA also encouraged consistency with the fresh-cut storage and temperature standards set forth in the FDA's Model Food Code of not greater than 41 degrees F / 5 degrees C. The draft guidance called for 40 degrees F / 4 degrees C. PMA noted in its comments that, with few exceptions, storage temperatures relate to quality issues. PMA cautioned that FDA's advice for items other than those identified as needing temperature control for safety (i.e. cut melons) may be interpreted by health inspectors and others as a safety rather than a quality issue unless there is clarification.
According to Means, "PMA encourages all members to have robust, active, verifiable food safety programs. Guidance such as this will help the industry refine and enhance existing systems particularly regarding FDA's emphasis on issues such as proper procedures, employee hygiene, water safety, and traceback.
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