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My name is Jim Cranney, from the U.S. Apple Association, and I wanted to thank FDA for the opportunity to come in today and say a few things from the industry standpoint. When FDA asked me to make a few comments, they asked me to address specifically research issues that are important for the industry and what the research orientation should be. Before I say specifically what those would be, I thought it might make some sense to just go back and look at this and sort of analyze really where we are.
When the first rule came out on the cider labeling, it really created a large change in the cider industry. We have been dealing with that for almost two years now, or going on three years. What has happened is that the larger and medium-size cider producers immediately converted to pasteurization.
What we've seen out in the trade -- in the industry, retailers and wholesalers of major supermarket chains -- is that they made it a requirement of their major suppliers to be able to supply what they considered to be a no-brainer, safe product. This means pasteurization, and they did it as soon as this became an issue three years ago. So essentially over the past three years what we've seen is that the major bulk of the supply of cider that's being processed in the industry has been subjected to pasteurization. Thus, at least you can say that there has been significant risk reduction from what we already had prior to the incident with Odwalla.
Where does that leave us? That leaves us essentially with a group of primarily smaller producers, in many cases very small producers, who do not pasteurize. I say this because it should have quite a bit of impact on the direction that USDA and FDA should take in terms of the research agenda that they follow.
It is not my intent to say specifically what the research ought to be. I'll let the researchers look at the whole spectrum of opportunity there. I do think, however that it does have to meet some really specific criteria. One criterion should be that it be practical. Controls should also be simple to implement by these types of small producers.
That means if you are a researcher and you get a very enlightened idea, to go down the research path. But then at the end you come to realize that it would cost the producer $20,000 or $25,000 to implement it, then I would say that it does not meet the criteria. The reality is that most of these producers are probably looking at a cost of between $5,000 and $10,000 at the most. If they were in a position to be able to expend $20,000 plus and dedicate those resources to the problem, there's a good chance that they would pasteurize.
It is important to understand that there's not necessarily a barrier out in the industry because the industry doesn't want to pasteurize. In a lot of cases, it's an economics problem. But in other cases, there really is a consumer demand for products that are not pasteurized, and that demand also has to be taken into consideration.
The other point that I wanted to make when we're working with these small producers, is whether we are really after zero risk? I think we get to a threshold policy issue here because we have to ask ourselves is the goal zero risk? And if it is really zero risk, then maybe there isn't any other answer.
Maybe there is no other solution besides pasteurization. But I would say that what industry is looking for here is a reasonable solution, and zero risk is not reasonable. There is precedent in regulations that say we don't have to have a completely zero risk.
Thus, I think that there still is room for these small producers to be able to produce their unpasteurized product. The amount of cider that these cider producers are producing in the grand scheme of things is small, but it's important to these individual cider producer because that is the source of income they need to sustain their own family. Cider producers over the last three years have been hurt in that area.
Although I was not here previously for the discussion regarding UV technology, I think that if the agency really is interested in significant risk reduction, this is a good area of focus. FDA should evaluate the petition that has been presented with significant vigor and expedite the petition review. Cider producers who want to utilize this technology should be able to do so without fear of some type of an enforcement action. I know specifically that there are many, many cider producers out there who would like to utilize this technology, but because of the regulatory hurdle, they are not able to incorporate it into their business.
My final point is not really research-oriented but it is communications oriented. I think that it is refreshing that we're finally talking about the science here and about data. Communication of science and data to the industry is important. I would like to encourage the agency to take the next step and go out to actually explain these types of issues to growers personally, and cider producers, who tend to be growers, at their winter meetings. Unfortunately, many of the producers that we need to communicate with are in the middle of growing a crop, and they're not in a position to get on an airplane and come to Washington, D.C. They are in the midst of fighting off diseases and pests, trying to thin, and get their operations in order to be able to actually harvest a crop.
I know there is a significant amount of interest among producers to hear this information. They're very motivated and they want to do a better job. I think that FDA could do a significant service to the industry if they went out to the meetings during the winter and presented the data that's been presented at this meeting. I think it would be a big step forward along the lines of communicating and having growers actually implement the practical risk reduction measures that can make a difference.
Thank you very much for the opportunity to be here.
