Regulatory Interaction

As part of its daily work, PMA interacts with U.S. government agencies and often responds to regulators' requests for industry comments on issues that affect the fresh fruit and vegetable industry. Below are PMA's recent comments on a number of topics.

• PMA Comments to the FDA on FSMA Re-inspection Fees for 2012 -November 30, 2011.
  Our comments to FDA addressed the notice setting fees for re-inspections, both domestic and foreign.
• PMA Comments to FDA on Preventive Controls for Registered Human Food and Animal Feed Facilities - August 22, 2011.
  Our comments to FDA addressed the development of guidance pertaining to hazard analysis, implementing and validating controls, and testing.
• PMA Comments to USDA on the National Leafy Greens Markerting Agreement - July 27, 2011.
  Our comments to USDA addressed a number of issues, including grower representation, communications, and food safety audits, in the agency's proposed voluntary agreement.
• PMA Comments to FDA on Food Safety Modernization Act: Inspections and Compliance Provisions - July 6, 2011.
  Our comments to FDA addressed the themes of risk profiles and commodity profiles, along with mandatory recall authority, informing consumers about recalls, and administrative detention.
• PMA Comments to FDA on Global Food Safety Comparability - June 30, 2011.
  Our comments to FDA addressed the complexity of the global produce industry and the role imports play in international trade.
• PMA Oral Testimony to FDA on Food Safety Modernization Act: Inspections and Compliance Provisions - June 6, 2011.
  Our testimony to FDA urged the agency to work closely with state and local agencies when it comes to FSMA inspections and compliance - as closer collaboration will allow for better operational efficiencies.
• PMA Comments to FDA on Food Safety Modernization Act: Preventive Controls for Facilities - May 20, 2011.
  Our comments to FDA urged the agency to use its existing resources as a framework from which to build new guidance and to work with industry to develop a comprehensive communication strategy on preventive controls.
• PMA Comments to FMCSA on Pilot Program on NAFTA Long-Haul Trucking Provisions - May 12, 2011.
  Our comments to FMCSA were supportive of the proposed pilot program cross-border trucking and the resolution of the trade dispute that has resulted from the failure to implement this program. (Comentarios en Espanol)
• PMA Comments to FDA on Food Safety Modernization Act: Title III – A New Paradigm for Importers - April 29, 2011.
  Our comments to FDA addressed the import provisions of the FSMA and how those will impact fresh produce.
• PMA Comments to USDA on Nutrition Standards for School Meals - April 8, 2011.
  Our comments to USDA addressed the new fruit and vegetable requirements for school meals, training issues, equipment needs, and more.
• PMA Oral Testimony to FDA on Comparability of Food Safety Systems and Import Practices of Foreign Countries - March 31, 2011.
  Our testimony to FDA urged the agency to ensure that food safety assessments can be completed as quickly as possible and with the least disruption to global trade
• PMA Oral Testimony to FDA on Food Safety Modernization Act: Title III--A New Paradigm for Importers - March 29, 2011.
  Our testimony to FDA addressed the new import programs mandated by the Food Safety Modernization Act.
• PMA Comments to USDA on PACA: Impact of Post-Default Agreements on Trust Protection Eligibility - September 20, 2010.
  Our comments to USDA addressed the PACA trust and said that post-default payment terms do not invalidate the seller’s rights under the trust.
• PMA Comments to FDA on Preventive Controls for Fresh Produce - July 23, 2010.
  Our comments addressed FDA’s open (now closed) docket to obtain information that will shape the development of safety standards for fresh produce at the farm and packinghouse and strategies and cooperative efforts to ensure compliance.
• PMA Comments to USDA, DHHS on Dietary Guidelines Advisory Committee’s Final Report - July 14, 2010.
  Our comments to USDA and DHHS stressed that the fruit and vegetable recommendations are critical to public health and that simple communications will not be enough to change behavior.
• PMA Oral Testimony to Dietary Guidelines for Americans Committee - July 8, 2010.
  Our comments to the committee called for a stronger, more vigorous effort for increased produce consumption through communication, social science, and policy changes.
• PMA Comments to USDA on Proposed PACA Fee Changes - May 10, 2010.
  Our comments to USDA supported the recommendations concerning proposed license fee increases for PACA.
• PMA Comments to FDA on Product Tracing Systems for Food - March 3, 2010.
  Our comments urged FDA to use existing standards and systems as they provide practical, real-world solutions.
• PMA Comments to Georgia Department of Agriculture on its Processing Food Safety Proposal - February 12, 2010.
  Our comments addressed a Georgia food safety proposal that would have adversely affected the produce industry (especially fresh-cut processors).
• PMA Comments to USDA on WIC Changes - January 28, 2010.
  Our comments commended USDA for incorporating a strong complement of fresh fruits and vegetables in the program that clearly advances a strong nutrition platform for WIC recipients, and offered USDA four suggestions for improving this important nutrition safety net for moms and kids.
• PMA Comments on FDA Draft Guidance to Minimize Microbial Food Safety Hazards of Leafy Greens - November 2, 2009.
  Our comments to FDA supported risk- and science-based federal regulation for produce safety that applies to fresh fruits and vegetables grown in or imported into the U.S. Beyond general rules for all produce, we supported the development of commodity-specific regulations for those commodities (in this instance, leafy greens) that FDA has identified as most likely to be associated with foodborne illness outbreaks.
• PMA Comments on FDA Draft Guidance to Minimize Microbial Food Safety Hazards of Melons - November 2, 2009.
  Our comments to FDA supported risk- and science-based federal regulation for produce safety that applies to fresh fruits and vegetables grown in or imported into the U.S. Beyond general rules for all produce, we supported the development of commodity-specific regulations for those commodities (in this instance, melons) that FDA has identified as most likely to be associated with foodborne illness outbreaks.
• PMA Comments on FDA Draft Guidance to Minimize Microbial Food Safety Hazards of Tomatoes - November 2, 2009.
  Our comments to FDA supported risk- and science-based federal regulation for produce safety that applies to fresh fruits and vegetables grown in or imported into the U.S. Beyond general rules for all produce, we supported the development of commodity-specific regulations for those commodities (in this instance, tomatoes) that FDA has identified as most likely to be associated with foodborne illness outbreaks.
• PMA Oral Testimony to USDA's proposed National Leafy Greens Marketing Agreement - October 20, 2009.
  Our testimony to USDA noted that a strong marketing agreement backed by the government would provide consumers with the assurance that robust food safety practices are in place for leafy greens.
• PMA Comments on FDA Transparency - July 28, 2009.
  Our comments to FDA asked the agency to work with state and local agencies to improve their capabilities and capacities to speed foodborne illness investigations. We also asked FDA to be as clear about the end of an outbreak, when it is safe to resume eating the affected item, as it is about the beginning of an outbreak when they tell consumers to stop eating a certain item.
• PMA Comments on FDA's Reportable Food Registry - July 24, 2009.
  In our comments to FDA, we called for improvements such as clarification of the phrase “reasonable probability,” reporting requirements and timeliness of report filing.
• PMA Oral Testimony on FDA Transparency Efforts - June 25, 2009.
  In our testimony to FDA, we recommended that FDA consult industry experts, both during calm times and during outbreaks, to better understand produce production and distribution and speed investigations.
• PMA Comments on FDA's Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables - December 30, 2008.
  In our comments to FDA, we strongly urged FDA to take a more proactive role in delivering on its regulatory responsibility to ensure the nation’s produce is as safe as possible. Specifically, we encouraged FDA to mandate Good Agricultural Practices (GAPs), among other issues.
• PMA Comments to USDA on Child Nutrition Reauthorization - October 15, 2008.
  Our comments encouraged USDA to take an expansive and innovative approach when addressing nutrition and the access and quality of the federal feeding programs.
• PMA Comments on FDA Third-party Certification Programs for Foods and Feeds - May 16, 2008. In our comments to FDA, we urged FDA to engage the produce industry across the supply chain for input on the certification process.