The National Potato Council has submitted comments to the FDA in response to proposed rules that would impact the potato industry as part of FDA's implementation of the Food Safety Modernization Act (FSMA).
The NPC argued the rules, Standards for Growing, Harvesting, Packing and Holding Produce for Human Consumption (Produce Rule) and Current Good Manufacturing Practice and Hazard Analysis and Risk Based Preventive Controls for Human Food (Preventive Controls Rule), are inconsistent in that they treat the handling and packing of raw potatoes differently based upon the location of the activities.
Although potatoes are considered a low-risk commodity under FSMA's Produce Rule if they are handled on an individual farm, NPC argued that "it is inconsistent to include the handling and packing of raw potatoes as a regulated activity in the Preventive Controls Rule, when those activities are identical to the handling of the same low-risk commodity in the farm setting."
"A low-risk raw agricultural commodity should retain its low-risk classification until it is transformed into a higher-risk commodity through processing or some other activity that increases its food safety risk," wrote NPC. "Comingling or relocating a low-risk agricultural commodity does not in and of itself change the risk profile of the commodity. FDA has not consistently applied their determination that potatoes as a raw agricultural commodity are low-risk to the Preventive Controls Rule."
The comments also called attention to NPC's recently released risk assessment guide, "Commodity-Specific Food Safety Guidelines for the Production, Harvest, Storage, and Packing of Potatoes," which provides guidance to companies that produce, harvest, store, pack and transport potatoes.
As part of NPC's efforts to make the industry aware of the guide's availability, last week it held a media call with trade press reporters, resulting in stories in The Packer, Capital Press, Produce News, Food Safety Magazine and other publications.
Due to technological challenges on the website www.regulations.gov, the comment period for the FSMA-related regulations has been extended by one week until Nov. 22.