Philip Derfler, Assistant Administrator
Office of Policy and Program Development
Jamie L. Whitten Building
1400 Independence Avenue, SW
Washington, DC 20250
May 24, 2010
RE: Notification, Documentation, and Recordkeeping Requirements for Inspected Establishments, FDMS Docket Number FSIS-2008-0025
Dear Mr. Derfler,
The Organic Trade Association (OTA) thanks you for this opportunity to comment. OTA is the membership-based business association for organic agriculture and products in North America. Its members include growers, shippers, processors, certifiers, farmers' associations, distributors, importers, exporters, consultants, retailers and others. OTA’s Board of Directors is democratically elected by its members. OTA's mission is to promote and protect the growth of organic trade to benefit the environment, farmers, the public and the economy (www.ota.com).
OTA strongly supports improvements in food safety, and the proposed improvements in quality systems are reasonable and workable.
FSIS proposes three requirements. OTA’s comments on those follow.
Require official establishments to promptly notify the appropriate District Office
that an adulterated or misbranded meat or poultry product has entered commerce
FSIS first proposes to require that every establishment make a written record of each reassessment of the adequacy of its process control plan, i.e., HACCP plan, or to document the reasons for not making a change to the HACCP plan.
This is not only a reasonable quality systems requirement, it is necessary in order to ensure that such plans are up to date. Organic operations must be inspected annually, with all updates noted, and covered operations under this proposed rule should also have a requirement for at least annual updating. This proposal shuld not be overly burdensome on certified organic producers or handlers.
Require official establishments to prepare and maintain current procedures for the recall of meat and poultry products produced and shipped by the establishment
FSIS also proposes requiring official establishments to promptly notify FSIS that an adulterated or misbranded product received by or originating from the establishment has entered into commerce, as well as preparing and maintaining current procedures for the recall of products shipped by the establishment if there is reason to believe that its products are adulterated or misbranded.
This is a reasonable precaution and should not be overly burdensome on certified organic producers or handlers.
Require official establishments to document each reassessment of the establishment’s process control plans, that is, its Hazard Analysis and Critical Control Point plans
This should be seen as part of a system of continual improvement and should not be overly burdensome on certified organic producers or handlers.
Thank you very much for your consideration.