Reduce Risk
May 25, 2011 
As the rules from the Food Safety Modernization Act (FSMA)begin to roll out, it will become more important than ever to pay attention to what will be expected of your operation to be in compliance with the law. Watermelon growers, who are producing a commodity that is in FDA’s “high risk” category despite never having a foodborne illness outbreak traced back to watermelon, must pay particular attention to what will be coming down the pike.
American Vegetable Grower caught up with David Gombas, senior vice president, food safety and technology at United Fresh Produce Association, to get some perspective on what is to come for watermelon growers.
Q. What has been the watermelon industry’s take on the “high-risk” treatment of watermelon by FDA despite the fact that no watermelons have ever been linked to a foodborne illness outbreak?
A. To be fair, FDA has not intentionally labeled watermelon as high risk. Rather, they have lumped watermelon into the “melon” category out of simplicity (How else do you put honeydew and cantaloupe, both of which FDA has linked to outbreaks, into a single category?) and a lack of awareness of unintended consequences.
Separating watermelon from cantaloupe and other netted melons is easy but, also to be fair, FDA has no information, beyond the lack of linkage to outbreaks, why watermelons have a different risk profile than honeydew. So why should watermelons not be lumped in with melons that have been implicated? If I was in the watermelon industry, I would be looking at honeydew, particularly the outbreaks FDA has linked to honeydew, and determine what went wrong, if it has been fixed, and if it is still a risk factor in honeydew, or watermelon, production today.
Q. From being lumped in with other melons, what is the financial burden on watermelon growers with regard to following food safety protocols?
A. Just to be identified as “high risk” has to have an impact on sales. Why would you choose a high-risk food when there’s a not-high-risk food available? Consumers’ love of watermelon fortunately trumps the high-risk label.
Buyers, on the other hand, are obligated to consider the high-risk label and take action. The key is for the watermelon industry to work with their customers to ensure that any extra efforts are actually useful and a good use of resources, not just superficial efforts that cost and do not improve food safety.
Q. Why are accurate record keeping and traceability programs critical?
A. If an operation can’t demonstrate, through record keeping, that they’ve done all the right things and complied with their own food safety plan, then they won’t be able to defend themselves if someone alleges that their product was contaminated or, worse, caused an illness. For most companies, 99.99% of the food safety records they keep will probably never be reviewed again. But for that one lot where it really matters, having the records might save them from a very expensive recall.
Another important point: Don’t bother keeping records unless they are kept consistently and they are accurate. If there is any indication that any of the records may not be complete or accurate, none of the records will be believed.
Record keeping is something that growers and handlers have not done enough of, so it will be more work and take more time than they are doing today. But record keeping does not have to be burdensome. Understand what is important to record and find ways to record, retain, and be able to access that information accurately and simply.
Q. Will the implementation of the Food Safety Modernization Act help to simplify the auditing process?
A. We’ve heard that the fresh produce industry — both suppliers and customers — have audit fatigue, and watermelon growers and handlers are not immune. That’s why we initiated the Produce GAPs Harmonization Initiative (see comments that follow). The FSMA requires FDA to publish a new proposed regulation this year with food safety requirements for fresh produce growers and handlers.
Congress told FDA to write this rule with a consideration of the food safety risks of the fresh produce commodities, recognizing that the 300-plus commodities we call fresh produce do not have the same level of food safety risk. So we don’t know yet whether or how watermelons will be affected by the proposed rule.
Q. Can you address the Produce GAPs Harmonization Initiative and the benefits it may bring to watermelon growers?
A. The “vision” of the Produce GAPs Harmonization Initiative is to develop a harmonized food safety standard and a checklist for GAP audits and a globally acceptable auditing process. The goal will be one audit by any credible third party, acceptable to all buyers.
We don’t expect that the harmonized standard will stop the multiple audits overnight or even in the first few years but, if we do this right, we believe that a common checklist and common interpretation of the expectations of operations will eventually drive a more common audit process.
Q. How far has this process moved forward?
A. Right now, teams of suppliers, auditors, and buyers are piloting the audit with several commodities — apples, potatoes, leafy greens, mushrooms, and grapefruit, to name a few. We have heard from all of the teams that the harmonized standard is reasonable, thorough, and, with some fine tuning, can be made to work for growers, packers, auditors, and buyers alike. We are collecting all of the comments from all of the teams, and the authors of the standard — the Produce GAPs Harmonization Technical Working Group — will consider those comments during their finalization of the standard in their next meeting in July.
At the same time, we know that certain buyers are requiring that any food safety audits be benchmarked by the Global Food Safety Initiative (GFSI). The GFSI addresses how an audit organization manages their internal quality assurance, which is outside the scope of the Produce GAPs Harmonization Initiative. But we are working with GlobalGAP and SQF (Safe Quality Food Program), both of whom have already developed policies that have been successfully benchmarked by GFSI, to adopt the harmonized standard.
Those organizations are reviewing the harmonized standard and will provide comments on any changes that will be needed for the standard to be acceptable to GFSI, and those comments will also be considered by the Technical Working Group in July. Getting a GFSI-benchmarked version of the standard will take a little longer, but we are hopeful that, with GlobalGAP and SQF both working on this, it will be available for use in 2012.
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