|
To Whom It May Concern:
These comments are provided on behalf of the American Mushroom Institute, a national
trade association representing the growers, shippers, and processors of cultivated mushrooms in
the United States, as well as suppliers to the industry.
In developing regulations to implement Sec. 281 of the Agriculture Marketing Act of
1946 (7USC1621 et seq.) as amended by Sec. 10816 of the Farm Security and Rural Investment
Act of 2002 (PL 107-171), we urge you to keep in mind the Congressional intent which is to
provide consumers at the retail level with information as to the origin of the foods they purchase.
We support this effort to provide consumers with as much information as possible about their
food choices.
We endorse comments submitted by United Fresh Fruit and Vegetable Association, the
International Fresh-cut Produce Association and the Produce Marketing Association regarding
the unnecessary complexity of the recordkeeping requirements in the voluntary guidelines.
Regardless of other commodities covered by this Act, perishable agricultural commodities
already operate under the Perishable Agricultural Commodities Act (PACA) with a
recordkeeping requirement of two years (7CFR46.14). Therefore, the mandatory regulations
should explicitly state that compliance with PACA also fulfills the recordkeeping requirements
of this law.
While this may have been the intent of USDA, the guidelines are not clearly written, on
this point and others. The decision to write guidelines that attempt to describe the obligations of
producers from such disparate commodities as peanuts, seafood, beef and produce has spawned
confusion and has complicated what, for perishable agricultural commodities, should seem
familiar and reasonable. We strongly urge the Department to separately address the requirements
for the various covered commodities so that all who produce, trade or sell those food items will
know their legal duty.
With regards to "markings," we would recommend that retailers have ample latitude in
the form of signs or placards for bulk displays. Consumers want a wide range of options from
packaged products to loose items they can choose for themselves and these regulations should
not add a burden to the retailer whereby these choices would be limited.
In sum, this law imposes obligations on links in the marketing chain. The penalties that
retailers face will likely also end up as a shared responsibility of growers, packers, shippers and
retailers. Accordingly, it is imperative that USDA provides rules that are clear and consistent
with existing laws and practices.
We appreciate this opportunity to provide our views.
|
