Jim Saylor - Comment

Document ID: FDA-2011-N-0921-0055
Document Type: Public Submission
Agency: Food And Drug Administration
Received Date: March 14 2013, at 12:00 AM Eastern Daylight Time
Date Posted: March 14 2013, at 12:00 AM Eastern Standard Time
Comment Start Date: February 19 2013, at 12:00 AM Eastern Standard Time
Comment Due Date: May 16 2013, at 11:59 PM Eastern Standard Time
Tracking Number: 1jx-8471-tx0d
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The restricted use of open water such as streams and ponds for irrigation and spraying should not be the same for all produce. I am referring to streams and ponds that the only source of contamination would be natural wildlife, not feed lots or holding pins for livestock. Crops like apples that do not absorb water through their peel and do not grow on the ground should be allowed to use open water for irrigation, spraying and fruit cooling up to a set number of days prior to harvest. Apples are covered with a natural wax that causes water to bead up and run off. Apples hang on the trees all season long, exposed to sunlight, oxygen and rain. With each rain the apples gets a fresh washing by nature. In addition to the natural cleansing the apples go through all season long they are washed in a solution of 200 PPM of chlorine in the packing house prior to packing. I have invested a large amount of money in overhead irrigation in my apple orchard to provide frost and freeze protection, soil moister and fruit cooling to prevent fruit sunburn on hot summer days so I can produce the highest quality fruit possible. My fruit has been tested time after time and has always come back 100% food safe. Produce such as apples should be allowed to use overhead irrigation at least up to 30 days prior to harvest. That would get us through the critical growing season and still be totally safe.

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