Sara T. DuPont - Comment

This is a Comment on the Food and Drug Administration (FDA) Proposed Rule: Standards for the Growing, Harvesting, Packing and Holding of Produce for Human Consumption

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To whom it may concern. In response to a grower question in regards to GAPs I spent considerable time a while back attempting to find regulation information as to what constitutes safe compost. To my knowledge there is no standard. This is likely because scientific studies showing how long it takes for bacteria in compost to be consumed by other organisms or diluted to non-detectable levels is highly variable and inconclusive.

Thus the part of the regulation which states that growers must "Growers, or commercial compost suppliers, must provide proof through laboratory testing that the composting process was adequate to make it safe to use" is going to cause much confusion. I don't think there is a scientifically based way to comply with this piece of the regulation.
Comment Period Closed
May 16 2013, at 11:59 PM ET
ID: FDA-2011-N-0921-0014
Tracking Number: 1jx-83bc-pkf9

Document Information

Date Posted: Feb 1, 2013
RIN: 0910-AG35
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Submitter Information

Category: Other Organizations - E0003