Edward Scott Horsfall [California Leafy Green Products Handler Marketing Agreement] - Comment

Comments regarding Docket No. FDA-2008-N-0455 – Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables; Request for Comments and for Scientific Data and information The California Leafy Green Products Handler Marketing Agreement (LGMA) is an organization formed to improve the food safety practices of leafy green growers and handlers in the State of California. Our 115 members ship approximately 99% of the lettuce and other leafy green products produced in the State of California. As members of the Marketing Agreement, LGMA members are required by State law to adhere to the requirements of the program, which include implementing Good Agricultural practices accepted by the LGMA Board of Directors. The LGMA supports updating the “Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables” developed by the FDA. California’s leafy greens industry has, in fact, already updated the 1998 FDA guidance document for lettuce and leafy greens, and believes our experience can serve as a model for how this can be done. We believe that Good Agricultural Practices must be commodity-specific, hazard- based and grounded in sound science. No single set of standards can effectively apply across the board, so the guidance developed or updated must be specific to commodity it addresses. Standards should be developed through hazard-based analysis by carefully evaluating and identifying risks associated with a specific commodity. Once complete, appropriate mitigation practices can be developed. To the extent possible, mitigation and control steps must be based on available science. Where new science is not available, best practices should be implemented. As new science becomes available, the standards should be constantly updated and improved. In 2006, the leafy greens industry in California created the California Leafy Greens Marketing Agreement, an organization designed to ensure that California leafy greens shipped to market were grown, packed and shipped according to a specific set of good agricultural practices. Starting with the 1998 FDA Guidance for lettuce and leafy greens, a group of industry scientists, food safety experts and others crafted the LGMA-accepted Commodity Specific Food Safety Guidelines for the Production and Harvest of Lettuce and Leafy Greens (a.k.a. GAP Metrics). . This set of food safety practices is now in place in the leafy greens industry in California, and has been successfully adopted for similar programs in Arizona and Florida. A national program, based on the LGMA model, is under consideration as well. A copy of the current LGMA-accepted GAP Metrics is attached to this letter, and we encourage FDA, in moving forward, to consider this effective model developed and implemented within the leafy greens industry.