As the U.S. Food and Drug Administration (FDA) works to strengthen the safety of the nation’s food supply, the produce industry offers its experience surrounding preventive controls and hazard analysis. The industry brings real-world practicalities to FDA’s development of guidance under the U.S. Food Safety Modernization Act (FSMA). PMA’s comments to the FDA’s recent request emphasize the industry’s commitment to food safety, especially to prevention. They identify the FDA’s proper role in the development of preventive controls within a food facility, regardless of size.

The FDA sought comments on information about preventive controls and other practices used by facilities that manufacture, process, pack or hold food to identify and address hazards associated with specific types of food and specific processes. PMA also offered comment on hazard analysis, validation, environmental monitoring, testing and small business considerations.

Industry members of every size and at every level in the supply chain are committed to food safety and share FDA’s focus on prevention. Because variability in size and operational practices present different risk profiles, one size preventive controls do not fit all. PMA stated FDA can play an important role by defining a framework of general expectations around how to conduct proper hazard analyses and the types of preventive controls or metrics that might be valuable. PMA also remarked that FDA, in partnership with the industry, should provide basic guidance to ensure operators of all sizes and levels of sophistication understand the fundamentals of risk-based food safety programs and preventive controls.

“Food safety programs can and must be scalable, and FDA rightly recognizes the needs of small businesses,” noted Kathy Means, PMA’s vice president of government relations and public affairs. “Every business that handles fresh produce must have a food safety plan, but these plans should be adaptable and not burdensome to small businesses. After all, the reality is that pathogens do not respect size or type of operation and consumers expect their fruits and vegetables to be safe—every time.”