2024 Comments
July 2nd 2024 -Water, FSMA Ag Water Rule Alignment
Produce Safety Workgroup, FMI- The Food Industry Association
Food safety remains a priority for FMI retail, wholesale and product supplier members. FMI on behalf of our members, supports the California Leafy Green Marketing Agreement (LGMA) advancing food safety guidelines based on the latest available science. Implementation of standards that are supported by science is essential for food safety and protecting public health.
As outlined in the California Leafy Green Products Handler Marketing Agreement, “the purpose of this Marketing Agreement is to license Signatory Handlers to certify safe handling, shipment and sale of leafy green products to consumers by adopting Leafy Green Best Practices.” Best practices are defined as “the commodity specific leafy green best practices document and the requirements contained therein, prepared by industry scientists, and reviewed by state and federal agencies, scientifically peer reviewed by a nationally renowned science panel and accepted by the Board.”
Over the course of the past two years, FMI has submitted comments and letters to LGMA urging the group to incorporate the latest science and best practices. Previous correspondence can be found at www.leafygreenguidance.com/submissions/.
With regard to these 2024 proposed changes, FMI is concerned that specific elements of science and best practices are not being incorporated. Details are outlined in the Word documents attached, as prescribed by the LGMA process. FMI urges LGMA to incorporate these details, especially programs around:
• Dead-End Ultra Filtration for Ag Water testing
• Periodic Equipment Cleaning for harvest equipment
• Quantitative Methods for Sanitation Verification of harvest equipment
• Validation of SSOPs for harvest equipment
FMI also recommends that all updates to the metrics are clear, concise and auditable.
We appreciate the opportunity to provide comments on the proposed changes. It is essential that the metrics are updated to include best practices informed by the latest scientific research.
Main Submission
July 2nd 2024 – Harvesting Equipment Sanitation
Produce Safety Workgroup, FMI- The Food Industry Association
Food safety remains a priority for FMI retail, wholesale and product supplier members. FMI on behalf of our members, supports the California Leafy Green Marketing Agreement (LGMA) advancing food safety guidelines based on the latest available science. Implementation of standards that are supported by science is essential for food safety and protecting public health.
As outlined in the California Leafy Green Products Handler Marketing Agreement, “the purpose of this Marketing Agreement is to license Signatory Handlers to certify safe handling, shipment and sale of leafy green products to consumers by adopting Leafy Green Best Practices.” Best practices are defined as “the commodity specific leafy green best practices document and the requirements contained therein, prepared by industry scientists, and reviewed by state and federal agencies, scientifically peer reviewed by a nationally renowned science panel and accepted by the Board.”
Over the course of the past two years, FMI has submitted comments and letters to LGMA urging the group to incorporate the latest science and best practices. Previous correspondence can be found at www.leafygreenguidance.com/submissions/.
With regard to these 2024 proposed changes, FMI is concerned that specific elements of science and best practices are not being incorporated. Details are outlined in the Word documents attached, as prescribed by the LGMA process. FMI urges LGMA to incorporate these details, especially programs around:
• Dead-End Ultra Filtration for Ag Water testing
• Periodic Equipment Cleaning for harvest equipment
• Quantitative Methods for Sanitation Verification of harvest equipment
• Validation of SSOPs for harvest equipment
FMI also recommends that all updates to the metrics are clear, concise and auditable.
We appreciate the opportunity to provide comments on the proposed changes. It is essential that the metrics are updated to include best practices informed by the latest scientific research.
Main Submission
July 2nd, 2024 – Water, FSMA Ag Water Rule Alignment
Arizona LGMA Technical Subcommittee
See attached files for proposed changes
Main Submission
Supplemental Materials
July 2nd, 2024 – Harvesting Equipment Sanitation
Arizona LGMA Technical Subcommittee
See attached files for proposed changes
Main Submission
Supplemental Materials
July 2nd, 2024 – Harvesting Equipment Sanitation
Dole – FSQA Team, Dole Fresh Vegetables
There are proposed changes and additions for each section. Too many to list here. Much of it has to do with frequencies, training. assessments, and self audits of programs.
Main Submission
July 1st, 2024 – Harvesting Equipment Sanitation
Harvest Forward Coalition, Submitted by Joe Stout Commercial Food Sanitation – Harvest Forward Facilitator
See attached file for proposed changes
Main Submission
Supplemental Materials
White Paper on Harvest Equipment Sanitation
June 28th, 2024 – Harvesting Equipment Sanitation
Gurmail Mudahar, Tanimura & Antle Fresh Foods inc.
The proposal is based on very specific type of equipment used to harvest and prepare raw materials for salad processing and does not apply to harvest equipment used for commodity produce that is significantly major portion of LGMA membership. Proposal also includes packaging materials sanitation and infrastructure, that is irrelevant to most of leafy green commodity business and the proposal is not based on risk assessment Hence the proposal is not implementable.
Main Submission
Supplemental Materials
June 20th, 2024 – Water, FSMA Ag Water Rule Alignment
Gavin Schroter, PrimsuLabs – Microbiology Lab Supervisor
No proposed changes to the document, but a question regarding the General Agricultural Water Management section. Will a template/form be provided for the creation of a written water assessment? I see that the reference to Appendix A was removed. An example assessment would be help as well to reference!
June 3rd, 2024 – Harvesting Equipment Sanitation
Harvesting Equipment Sanitation Working Group
On behalf of the Harvesting Equipment Working Group, we are submitting the following amendments to Issue 8 regarding Harvesting Equipment and Sanitation The key changes are:
- Inclusion of 7 Steps for Cleaning and Sanitation: Standardized procedural steps for cleaning and sanitation. This includes a preparation table (Table 5), and a table with the 7 steps, best practices, and day of harvest procedures (Table 6)
- Self-Assessments Against Issue 8: includes training requirements for personnel conducting the self-assessment. (Training requirements added to Issue 4)
- Sanitation Crew Training Requirements
- Annual Hygienic Design Review.
- Language Updates to Align with AZ LGMA
- Modification to Metrics for Improved Organization and clarity.
The proposed changes document includes all changes made by the working group. The text in red represents added or removed text. The text in blue a comment regarding the modifications.
Please submit your comments as Word document comments by clicking on the “Submit a Comment”
June 3rd, 2024 – Water, FSMA Ag Water Rule Alignment
Water Metrics Working Group
On behalf of the Water Metrics Working Group, we are submitting the following amendments to Issue 6 Water Metrics The key changes are:
- Update the text for alignment with FSMA Final Rule on Agricultural Water. This includes the inclusion of language related to crops characteristics susceptibility to adhesion and internalization, inclusion of a written agricultural water assessment, and additional information on degree of protection from possible sources of contamination.
The proposed changes document includes all changes made by the working group. The text in red represents added or removed text. The text in blue a comment regarding the modifications.
Please submit your comments as Word document comments by clicking on the “Submit a Comment”
The 2024 LGMA Approved Guidelines Amendment Process
Western Growers supports the continuous improvement of the LGMA-approved leafy green food safety guidelines and facilitates a yearly systematic amendment process.
Starting in 2022, the “Priority Setting Committee,” established by the LGMAs, is responsible for assessing annual priorities. At the beginning of each year, the Priority-Setting Committee sets the topic(s) for the remainder of the year.
Submit Comments
Important Documents
Harvesting Equipment Sanitation Working Draft (Download Here)
Water Working Draft – FSMA Ag Water Rule Alignment (Download Here)
Participate in the Process
If you are interested in summitting comments to for the proposed working drafts, follow these submission guidelines:
- Download the “Working Draft” under Important Document
- Use the Word function “New Comment” to provide details on how the proposed change will enhance food safety, along with the rationale behind the change
- When you are ready to submit please submit your document by clicking on “Submit a Comment” button below. This will take you to a form where you can attach a new version of the working draft with your comments.
Note: We are only accepting proposals that follow the above steps. Comment should be submitted as a word document, scientific rationale should be included for comments submitted.
Important Dates and Events
| Event | Dates | Details |
|---|---|---|
| Priority Setting Process | Jan 15th – Mar 1st | Find a copy of the report and supplemental documents |
| Priority Working Process | Mar 1st – May 31st | WG and CA LGMA select the Priority working group. WG facilitates working group meetings. The priority working group proposes science-based changes for the set priority. |
| Comment Submission Process Begins | June 3rd | Comment period begins. WG, LGMA announce comment period being open |
| 30 day – comment period | June 3rd – July 2nd | The public submits comments through this website |
| Webinar – review comments and proposed changes | July 11th at 1 PM PT | WG hosts a webinar. Public comments are reviewed and vetted
Register here |
| Final Report | July 15th | WG prepares a report of comments and public vetting for the CA LGMA board to consider and discuss |