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Comments on the Cider Crisis By Alica Rosamilia
Reprinted from the apple-crop
e-mail discussion group at
The Virtual Orchard |
Date: Sat, 28 Feb 1998
From: Alica Rosamilia
Subject: Re:Cider Risk Assessment-What to Do About It
To: apple-crop@www.virtualorchard.net/
Dear Apple-Croppers:
I am a law student and have been studying the cider
issue for a directed
research project. I also went to the New England Fruit Meeting & Trade
Show.
Did you go to the panel discussion on "The Latest Update on the Cider
Industry"? The FDA representative wanted everyone there to understand
that
the government is under pressure to get a final rule in place in time for
the
'98 cider season, and invited the industry's comments. In my opinion, apple
cider producers have a great argument against the 5-log reduction, which
would
require pasteurization, and that is the same argument you have made:there
has been no risk assessment or other scientific study that warrants a
requirement as drastic as pasteurization.
Pasteurization may put many small
producers like yourself either out of business or erode their business
severely. The proposed warning labels are worse because they will only alarm,
not inform, the public. Fresh apple cider is a safe and healthy product
when
produced using good manufacturing practices. Consumers also deserve a choice,
and as your "home study" proves, most prefer unpasteurized apple
cider, not
apple juice!
So what can you do about it? Do what the FDA representative
said at the New England Fruit Meeting:make your argument to the
FDA. As
citizens, you should be worried that a federal agency can create a regulation
that will put you out of business when the risk hasn't been assessed, but
you
can successfully lobby against food safety groups, because your product
is
safe. You are presenting very good issues to the Apple-Crop e-mail discussion
group, but not to the FDA.
As a matter of administrative law, the
FDA must
review the comments submitted to it in forming a proposed rule. I have
critically reviewed every single comment sent to them in response to the
FDA
Notice of Intent published August 28th. In general, the comments submitted
make the same arguments you make, but there are very few comments; only
30 or
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