Howard F. Schwartz - Comment

As a pest management and vegetable production specialist working with the dry bulb onion industry and its growers, I request that the FDA use the long-established EPA Crop Group (instead of water system) designations that have accepted compliance between federal, state, industry and consumer groups with relevancy to botanical characteristics of crops, their established production practices including water systems used for irrigation, and post-harvest chemical residue allowances. A listing of these EPA crop groups is available at http://ir4.rutgers.edu/other/CropGroup.htm