Arthur Y. Kishiyama - Comment

I represent an organization of primarily small, grower/producers of olives and olive oil. Our concern is that the Proposed Rule will impose an expensive and unnecessary risk assessment process on our farm-based operations. The Draft Qualitative Risk Assessment does not consider the production of olive oil. Juice is extracted from the fruit of the olive tree without heat or chemicals to produce virgin and extra virgin olive oil. Biological hazards are not associated with olive oil and is thus considered a potentially non-hazardous food in the state of California. It is not reasonable to assume that the production of olive oil will cause adverse health consequences to humans. The Olive Center at the University of California at Davis has published a study on the Microbiological food safety of olive oil (attached) which concludes that “based on the currently available literature, food borne pathogens are not likely to occur in extra virgin or virgin olive oils”. For these reasons, the Draft Qualitative Risk Assessment should identify olive oil as a low risk activity/food and add it to the list of exempt foods such as honey and seed oil in the Proposed Rule.