Thanks to Tom Karst of The Packer for taking the time to read submissions to the U.S. Food and Drug Administration as the agency contemplates preventative controls for fresh produce.

Christine Bushway, Executive Director of the Organic Trade Association (OTA) says “organic agriculture is the most highly regulated system of agricultural production in the U.S., and the USDA-accredited verification system, especially its recordkeeping and inspection requirements, should be recognized and considered by FDA when drafting rules requiring similar features.”

Lots of record-keeping does not mean lots of food safety.

Bushway also says, “the organic system offers an integrated process approach to preventive food safety practices that could stand as a national model for both farming and manufacturing operations. The organic process already contains many steps that contribute to food safety processes and it can be easily integrated into a more elaborate food safety system – especially in processing.”

That’s true, and we said as much back in 2004 (see below). But why is it up to everyone else; why don’t organic processes expand so they can be considered a more rigorous or even certifiable food safety program?

The potential for microbial contamination along the food production chain exists for both conventional and organic food products. Water quality, soil amendments such as composted manure and general sanitation need to be monitored and verified in any food production system. Organic certification is not a food safety certification.

Microbial food safety considerations for organic produce production: an analysis of Canadian Organic Production Standards compared with U.S. FDA guidelines for microbial food safety,” by K.A. Blaine and D.A. Powell. Food Protection Trends 24, no. 4 (2004): pp. 246-252.

Increased attention has been focused on fresh fruits and vegetables, especially raw or minimally processed, as a significant source of foodborne illness. Outbreaks have been linked to both conventionally and organically grown produce. This paper outlines the risks associated with fresh produce, common pathways of contamination, and current trends in organic agriculture. The primary objective was to determine whether the Canadian General Standards Board (CGSB) organic standard is consistent with the production of microbiologically safe produce and to examine the potential for the CGSB organic standard to include considerations for microbial food safety. This objective was achieved by examining information gaps between the US Food and Drug Administration on-farm food safety guidelines and the organic standard developed by the CGSB. This examination showed a significant degree of commonality and, in some cases, it was demonstrated that microbial food safety standards are achieved indirectly under organic production. The main difference between the U.S. guidelines and the CGSB standard is the focus on the process rather than the safety of the final product,and the lack of discussion of microbial considerations in the CGSB standard. Specific omissions include worker hygiene and recommendations for safe use of processing and irrigation water. The production of safe food is the responsibility of everyone in the farm-to-fork chain. With established relationships between growers and regulatory infrastructure, the CGSB organic standard would be an ideal vehicle for providing organic growers with information and guidelines on identifying and controlling microbial hazards on their produce.