Beth Bland of the Goegia Fruit and Vegetable Growers Association makes some interesting points in her comments to the FDA. See:

The association voices the opinion of many that third party audit schemes have taken a life of their own and now constitute a greater burden for the primary producer than is necessary to ensure food safety. Please see my letter to the associaition in response

Dear Ms Bland:

I read your good comments circulating now and your thoughts on third party audit schemes. The issues you brought up are real and need to be addressed.

The third party audit model should not take the place of government inspection. Only government inspectors have legal authority to protect the public. Third party schemes have developed to protect the buyer in the absence of government regulation, as you have correctly opined. Third party audits do in fact also protect the public, but a third party auditor cannot stop an unsafe operation, embargo a product or enforce a recall. These powers to protect the public are clearly the governments’ job. Additionally, some buyers might go around the system when they need product.

As a third party auditor, consultant and former regulatory official, I have seen both sides of the picture. The business of food safety has many problems. I believe that if FDA eventually has the manpower and the authority to enforce GAP standards, the buyers will accept a satisfactory FDA inspection as an indication that the firm has food safety programs in place. The third party scheme will eventually become a best practices model that the buyers can use to separate the good, from the best. Third party audits will not go away because buyers want assurance that the infrastructure of the organization is soundly built around food safety. Government inspectors do not go that far, looking only at the facts about sanitation they see during the inspection, and this snapshot does not tell the whole story.

The two systems together will deliver both the assurance that bad operations do not continue to operate, and will satisfy the buyer that the integrity of the food safety management system is in place for the good and best operations. I believe a scaling back of third party audits will generally take place and my role will change to more consulting and less auditing

I commend you and you organization for supporting food safety, and your sincerety. I was in Tifton Ga., with Kiley Harper (RC Hatton), for the meeting with FDA this spring and your industry was well represented and very well informed. Both Kiley and I were on the water safety panel and we addressed many of your concerns about water quality and how to measure it, but we certainly do not have all the answers. Most irrigation water systems I see have no problems meeting the LGMA standard, but we do not see a lot of foliar application of surface water here in Florida, either.

We do not have a definitive answer as you know, on what constitutes a good irrigation water test result; or at what level of bacterial indicator we should expect a pathogen, or more fundamentally, the best indicator. Only applied research over a long period can establish this in produce irrigation water, if at all.

On the up side, we are seeing a big improvement in produce borne outbreaks, not having a large scale domestic incident for quite some time (since peppers/tpmatoes).

Positive actions by you and your group are accomplishing much and food safety folks like myself appreciate what you are doing.

Thanks very much.