Comments
Georgia Department of Agriculture
Proposed Rule: Additional Regulations Applicable to Processing Plants
February 18, 2010
Mr. Oscar Garrison
Assistant Commissioner
Consumer Protection
Georgia Department of Agriculture
19 Martin Luther King, Jr. Drive, Room 321
Atlanta, GA 30334
Via E-mail: Natalie.adan@agr.georgia.gov
Re: Rule 40-7-18-.01 Additional Regulations Applicable to Processing Plants
Dear Mr. Garrison:
The North American Millers’ Association (NAMA) appreciates the opportunity to comment on the recently published rule 40-7-18-.01 that creates additional regulations for food processing facilities in compliance with Senate Bill 80. The North American Millers' Association is the trade association representing the wheat, corn, oat and rye milling industry. NAMA’s 45 member companies operate 170 mills in 38 states and Canada. Their aggregate production of more than 160 million pounds per day is approximately 95 percent of the total industry capacity. Our member companies operating facilities in Georgia -- ConAgra Mills (Macon), Milner Milling (Milner), Southeastern Mills (Rome) -- play an essential role in Georgia’s agriculture, utilizing a significant percentage of Georgia’s approximately 270,000 acre wheat crop.
The grain milling industry is committed to food safety. Our food safety programs are designed to help maintain product integrity throughout the entire milling process. Anticipating and preventing unintentional contamination before it occurs is the foundation of the modern, science-based process. That process includes: Hazard Analysis and Critical Control Point (HACCP) programs, Good Manufacturing Practices, and routine 3rd party audits. We support the aspects of the proposed rule, such as Section 40-7-18-06 (c), that allow individual companies to use their expertise and knowledge of industry practices to determine the best way to build food safety into their system. Along the same lines, we believe it is very important for plants to have flexibility in implementing the requirement to separate raw foods from ready-to-eat foods. In some cases, “raw” materials may have had some processing and may be appropriate for a processed area.
We also support the concept in SB 80 and the proposed rule that acknowledges the importance of written food safety plans as a critical element to any successful food safety system. It is important to understand, as we believe the proposed rule attempts to do, that not all food safety plans should be identical. Important distinctions may need to be made based on varying manufacturing processes, product types and facility differences. Though the proposed rule gives facilities discretion in creating their own individual plans, it would appear that the Department has interpreted SB 80 to mean that all plans must include some level of finished product testing to be effective. NAMA strongly disagrees with this interpretation of the law, as there are more proven ways to effectively ensure food safety throughout the manufacturing process, particularly for low risk product such as flour.
The proposed rule defines “Raw Agricultural Product” as one that has undergone little or no processing and would require further processing before consumption. All wheat flour, including that produced in Georgia, is intended to be baked, fried, cooked or treated prior to consumption. It is not produced for human consumption in its raw state. The vast majority of flour produced in Georgia goes into commercial channels, such as bakeries, where there is a kill step. Retail flour customers also bake, fry or cook the flour prior to consumption.
NAMA agrees with the distinction made in the rule that exempts raw agricultural products from having to comply with state-mandated testing and reporting regimens and believes wheat flour should be defined as a raw agricultural product as defined in the rule. Our industry strongly believes that finished product testing of products that are not intended for direct human consumption, particularly a low moisture product like flour that does not promote pathogen growth, will not provide useful information to the manufacturer or the Department of Agriculture. While we understand and appreciate the intended goals of such testing, any confirmed reported positives of raw products may only serve to distract agency resources from identifying real areas of concern.
We take very seriously our responsibility to ensure that the wholesome products produced in our mills are not compromised. Our reputation as suppliers of safe, wholesome milled grain products is our most valuable asset. Protecting food safety is our most important job. We would welcome the opportunity to discuss the proposed rule, as well as the food safety efforts of the milling industry, with you in more detail. Thank you for your consideration of our comments.
Sincerely,
Betsy Faga
President
Georgia Department of Agriculture’s response
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