Daniel A. Andrews (Dan Andrews Farms LLC) - Comment

Document ID: FDA-2011-N-0920-0002
Document Type: Public Submission
Agency: Food And Drug Administration
Received Date: January 16 2013, at 12:00 AM Eastern Standard Time
Date Posted: January 16 2013, at 12:00 AM Eastern Standard Time
Comment Start Date: January 16 2013, at 12:00 AM Eastern Standard Time
Comment Due Date: May 16 2013, at 11:59 PM Eastern Standard Time
Tracking Number: 1jx-835a-4m6k
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As a grower of fruits and vegetables in California, I am well aware of the challenges of bringing quality product to the marketplace. My concern with the Proposed Rule, is one of liability to the grower. It seems unfair that growers are liable from "womb to tomb" or from field, to hauling, to warehouse #1, then back on another truck to direct store drops. Much handling occurs in this process which brings into play more chances of bacteria that are not caused by the grower. However the grower is the one who has to accept responsibility and defend himself in lawsuits. Therefore I urge you to hold accountable for good practices policies for all components of the food chain, not limited to the grower.

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