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Consumer Comments on Food Irradiation 5*** RE: Docket: AMS-FV-07-0090, Food Safety Regulations for Leafy Greens Under the Agricultural Marketing Agreement Act of 1937 (AMAA) Document: AMS-FV-07-0090-0001, Handling Regulations for Leafy Greens Under the Agricultural Marketing Agreement Act of 1937
I absolutely do NOT want my ability to purchase fresh, natural COMPLETELY RAW
leafy greens in this country taken away!!! And yes, required 'pasteurization'
(through irradiation or otherwise) of leafy greens will compromise my ability to
do so.
Here's an idea-- Instead of making consumers pay for big agricultural
businesses' profit margin by having to buy food that's had its beneficial
enzymes and nutritive value altered, why don't y'all instead require big
agriculture to act responsibly and adhere to properly hygienic handling
protocols and enact better shipping practices so that the food is harvested,
packaged, transported and delivered to the consumer in truly clean, fresh and
healthy condition to begin with? Laurie A Barrow Dallas, Texas
*** As a longtime consumer of locally grown organic leafy greens, I feel that regulation should be handled on a local basis.
The program's handling regulations should specifically address companies that are
distributing greens nationally since any contamination of their greens has the
potential to affect a much larger population.
Large growing and processing operations that are located within watershed areas
that include stockyards, meat processing plants and other sources of chemical
and bacterial toxins is a practice that should raise a red flag at the USDA, and
those companies should merit close scrutiny. Regulation should take place at the
beginning of the production cycle, starting with where the farms and packing
plants are located, rather than the final packing stage. It just makes better sense.
Ultimately, food supply issues such as the recent e.coli contamination cannot be
controlled by additional rules and regulation. There must be a common-sense
approach to production practices that is realistically enforceable, and the most
important way for the USDA to protect the consumer is by requiring truth in
labeling. If the consumer knows the conditions under which food is produced, if
the label "ORGANICALLY GROWN" could be trusted to ensure a safe growing
practices, it would enable consumers to make good decisions to protect
themselves. Without truthful labels and adequate information, consumers will
continue to be at risk.
I protect my family by buying locally grown produce directly from the farmers at
the farmer's market as much as I can. These farmers need the support of the
USDA, not regulations that would require irradiation of chemical treatment,
practices which are in conflict with healthy and sustainable farming practices.
Thank you. Kathy Gulrich
***DEAR SIRS,
THE PROPOSED REGULATION AMS-FV-07-0090 MIGHT WELL ADDRESS A
POTENTIAL RISK OF BACTERIAL CONTAMINATION, SUCH AS RECENT OUT
BREAKS OF E. COLI STRAINS. HOWEVER, MINIMIZING THIS RISK BY INTRO
DUCING OTHER UNTOLD RISKS ASSOCIATED WITH SUCH PRACTICES AS
"PASTEURIZATION" BY IRRADIATION IS A POOR SOLUTION. THERE IS NO
CONVINCING EVIDENCE THAT SUCH A PRACTICE IS BOTH "SAFE AND
EFFECTIVE" OR THAT IT HAS NO ADVERSE EFFECTS ON THE FOOD
SUPPLY IT AIMS TO PROTECT. IMPOSING THIS REGULATION ON POWER-
LESS CONSUMERS WITHOUT PUBLIC DISCOURSE IS AS IRRESPONSIBLE
AS IT IS UNCONSTITUTIONAL. I URGE YOU TO REJECT THIS PROPOSAL.
SINCERELY, PAUL BLACKBURN, RPh.
***

We Oppose
Food
Irradiation!
*** Aloha, As an Acupuncturist, I am explaining all the time to my patients and friends how very important leafy greens (especially grown under organic conditions) can eliminate or greatly improve many forms of disease in American patients. I know that it can make a life or death difference in some people's cases.
The idea of ruining all the nutrients in these special foods is crazy beyond belief! Please do not support this action and do not allow it to be pushed through by those who do not understand what damage they will cause to people who need to eat green leafy vegetables.
I DO NOT support packers, processors, shippers, and marketers
(collectively referred to as handlers) in their choice to use pasteurization,
irradiation and other forms of unnatural processing to maintain the
quality of their products they offer. These methods may reduce the risk of
pathogenic contamination during the production and handling of leafy greens, but
they will surely eliminate most of the nutritional value for us human beings.
Agri-business and the big corporations who use unhealthy practices to cut the
cost of instead of using hygienic handling practices and more prudent shipping
methods. If it costs more, that is a cost they should pay rather than passing the
burden on to public in the form of food that has had most of the nutritional value
killed in the way they market the once alive food!
Mahalo, Dr. Keola G.A. Downing, L.Ac., Ph.D.
***Re: Docket ID AMS-FV-07-0090
Federal Register pages 56678-56680, vol. 72, no. 192, October 4, 2007
Dear USDA Agriculture Marketing Service,
PLEASE NO IRRADIATION!!!!! I WANT MY RIGHT TO NATURAL ORGANIC FOOD TO BE A GIVEN!
Thank you for the opportunity to comment on the Advance Notice of Proposed
Rulemaking for a Marketing Agreement for Leafy Greens. I am concerned with the
proposed rulemaking for several reasons.
First, I believe that neither a Marketing Agreement nor a Marketing Order are
appropriate models when seeking to protect food safety on a national scale. Both
models would allow a small board of processors and handlers to set the rules for
all farms in the nation who wish to sell their vegetables to processors. It puts
disproportionate power in the hands of large operations and corporations, who
would most likely be represented on these boards. This board would be given the
government-sanctioned authority to dictate the growing practices for all other
farms?large or small?in the nation, which I believe to be an inappropriate model
and level of authority.
I am also concerned that appropriate guidelines, suitable for small as well as
large farms, have not yet been developed. I encourage the USDA to delay the
implementation of federal standards until scientifically proven methods for
reducing E. coli 0157 contamination have been demonstrated. The California
Leafy Green Marketing Agreement (LGMA) guidelines have already been implicated
in two recalls, showing that more research is needed before a set of uniform
standards can be required throughout the nation.
Furthermore, federal regulations would discriminate against many farmers who
employ organic farming practices and farmers who promote biodiversity on farms,
as has been the experience with the California guidelines. The adoption of such
rules on a national level would harm the environment, and more environmentally
friendly guidelines must be developed if they are to be mandated nationally.
I would also like to note that the risk of E. coli 0157 contamination comes
predominantly from ?fresh cut? lettuce and spinach? the pre-washed, pre-cut bags
of greens that have recently become so popular. Therefore, even if the USDA were
to require standardized growing practices, it should apply only to large-scale
suppliers of ?fresh-cut? bags of leafy greens, and exclude whole leafy greens
that have never been implicated in an E. coli 0157 outbreak, such as kale,
arugula, and chard. A one-size-fits-all approach is totally inappropriate in
addressing this important health and environmental rulemaking proposal.
If federal guidelines were to be enacted, there should be an exemption based on
scale? small-scale farmers should not have to follow the same rules as
large-scale operations that have been responsible for past widespread
contamination. Moreover, exemptions should exist for traditional farmers selling
locally and for farmers with organic certification. Although no fresh food
production is risk free, the smaller operations, with hands-on management, pose
an infinitely smaller risk to the nation?s citizenry.
Finally, I oppose the proposed Marketing Agreement because it would likely be
costly and overly burdensome to small- and medium-scale growers and could
potentially drive these farmers out of business. As a consumer of leafy greens
and a supporter of environmentally sustainable, local food systems, I urge the
USDA to not support one-size-fits-all requirements that would dictate to farmers
how to grow their vegetables, especially when such guidelines are not evidence
based and are written by and for large-scale operations?farms, that based on
past experience, might very well need additional regulatory oversight.
Thank you for your consideration.
Sincerely, Christine Hodil
*** I am against irradiating food. Yes, they say it will insure against e. coli. However, irradiation changes the atomic structure of the food, and it kills good bacteria our bodies need. Killing bacteria in food could very well be tantamount to killing ourselves! Don't mess with what nature has provided; we can't presume to, and never will understand everything and we must be careful about doing something that cannot be undone and having disasterous results!
*** I am against irradiation of my foodstuffs in general, my leafy greens in particular. I feel that irradiation will change the molecular structure of the foods and compromise the nutritive values. Radiation is destructive of cellular structure, deadly to enzymes and vitality. While it may reduce the number of pathogenic bacteria, it also reduces the numbers of beneficial bacteria, reduces the activity of the immune system against pathogens contained therein, and exposes the public to greater harm in the event of a large number of pathogens accidentally introduced in any medium.

If the goal is to ensure the public safety, may I suggest more care be taken in
the growing and handling of the materials. Label foods as to country of origin
so that we can choose to buy from areas that are more likely to follow hygienic
growing standards. Every individual has the possibility of washing vegetables at
home and/or cooking or sterilizing on an individual basis, leaving the greater
food supply uncontaminated by radiation and the unknown hazards of "fooling
Mother Nature", which as we know, is not smart.
***Concerning Docket ID AMS-FV-07-0090 on page 56678 of the October 4, 2007
Federal registry Vol 72 No. 192, I am vehemently against the pasteurization or
irradiation of any leafy greens or any other raw vegetables as this would
seriously affect the nutrition of these foods. There are better ways to make
sure vegetables are safe to eat than cooking all the nutrients out of them.
People who like raw vegetables should be able to buy them that way. If they want
to take a chance on the foods being contaminated that is their business and they
do not need the USDA or any other government agency playing daddy. There are
perfectly good ways to thoroughly clean vegetables without heat or microwaves
and people who eat a lot of their vegetables raw already know what they are.
***Aloha, Leafy green vegetables are extremely important to my diet.
In fact, fresh organic leafy green vegetables are saving my life!
I am NOT in favor of packers, processors, shippers, and marketers (collectively
referred to as handlers) using pasteurization, irradiation and other forms of
unnatural processing to maintain the quality of their products and reduce the risk
of pathogenic contamination during the production and handling of leafy greens.
I want the agri-business corporations to take responsibility and use more hygienic
handling practices and more prudent shipping methods, even if it costs them a
little more, rather than passing the burden on to me in the form of toxic, devitalized food devoid of most of its nutritional value.
*** I am opposed to any mandatory requirement that Leafy Greens be pasteurized and/or irradiated. It is not clear to me that the Handling Regulations for Leafy Greens Under the Agricultural Marketing Agreement Act of 1937 will be changed to
require mandatory pasteurization or irradiation. I am opposed to any rules that
would make pasteurization or irradiation mandatory for all food processors. I
feel that consumers should always have the option of purchasing leafy greens
that have not been irradiated or pasteurized.
***I am writing to urge you not to rush through regulations requiring the "pasteurization" of greens,
which I believe to be a euphemism for irradiation-- an extremely unhealthy thing to do with our most natural and healthful foods. This issue requires adequate public comment, and small farmers need time to properly understand what is being requested of them. Surely it makes more sense to give everyone a chance to propose better ideas for ensuring the safety of America's greens. Pushing
legislation for "pasteurization" of greens forward is NOT the answer.
Thank you for listening, Lisa Henderson Davis, CA
***Dear DoA:
I am horrified to learn you are considering mandating the irradiation of leafy green vegetables to be sold in the US! I thought American values included freedom of choice, as well as health and safety, and education to rectify unsafe situations where possible. I eat 80% raw and organic foods by choice and
for health reasons, and "pasteurizing" (or irradiating) greens would make it impossible for consumers such as myself to choose to eat raw, untreated vegetables on which we rely for our health.
Require agro-business to use more hygienic handling practices and more prudent
shipping methods, even if it costs them a little more, or require a warning label on produce if you must, but please do not toxify our food supply!
Thank you for our consideration of this important, if under-represented, viewpoint. Sincerely, Sherry Zitter, MSW, BCD
*** The use of irradiation to cleanse leafy greens or almonds or any natural foods of contamination (presumably e. coli) may lessen the risk of such contamination at the expense of nutritional value of the food itself. The questionable practice will inevitably cause suffering to the farmers and retailers because I and many others will no longer purchase these unnatural foods. Furthermore, to my knowledge, there is no convincing evidence that such "pasteurization" is free of health risks
and this risk may well outweigh any benefit realized by this proposed regulation.
This option should be a human choice not a law forcing everyone to eat only
irradiated foods. Give people the choice with labels "pasteurized"
or "unpasteurized" . Let us take the risk.
***I am strongly opposed to the proposed rules requiring "pasteurization" or irradiation of leafy greens.
These are basic nutritious foods that we depend on for vital nutrients which would be completely destroyed by the proposed "safety" treatments of these greens. Hygienic handling practices would go a long way to assuring food safety, rather than imposing requirements of procedures that rob the food of its intrinsic nutritional value. Irradiation violates organic practices, is toxic and detrimental to human health. Why grow foods only to basically destroy their value to health before they ever get to anyone's plate? Please stop this attempt at reducing the vital food supply and safeguard the organic greens and conventional greens that we depend on for calcium and other essential nutrients. Sick procedures lead to sick people, presumably the opposite of what we hope to
achieve in growing food!
***USDA proposed regulations re: Food Safety Regulations for Leafy Greens Under the Agricultural Marketing Agreement Act of 1937 (AMAA)
Potential treatments of Leafy greens or other produce vegetables, fruits, etc.
I am against any and all forms of pasteurization, high temperature treatments,
chemical treatments with any potentially harmful toxins, pesticides, herbicides,
fungicides, cancer causing chemicals, radioactive or x-ray treatments and
irradiation of any of my foods to include all leafy greens, dairy, seeds, nuts, fruits, vegetable, produce, herbs, sea vegetable, plants,
I believe that all treatments be fully disclosed to the highest standards available.
I am also against Codex Alimentarius and other regulations that restrict and
reduce my rights to chose my foods, nutrition, supplements, herbs, vitamins and
other sources of natural health and wellness.
Thank you for protecting my rights and health freedoms to choose what is best for
me.
Humans have lived for thousands of years without these treatments and we may
continue to live for thousands of years if we stop interfering in the natural system and perfect system our creator provided for us.
Please remember government for the people and by the people.
Alcohol, drug reactions, prescriptions, over the counters, toxic industrial
chemicals, pollution, doctors errors, hospital infections, cancer, heart disease,
diabetes, malnutrition, accidents, contaminate water, contaminated meats and
wars kill far more people than any likely problem with leafy plants.
Thanks again for using common sense and trusting in our creator and the natural
healing power of the human body to do what it was designed to do to survive.
***In reference to proposed rules,docket ID AMS-FV-07-0090, handling regulations for leafy greens,please do NOT allow our leafy greens, ESPECIALLY organic greens ,get irradiation, this would destroy the food value, cause cancer and ruin the value of the organic label, if this happens , litigation will certainly follow and the courts are clogged enough with other issues, please do NOT put these rules in place!!! The proposed rules are obscene and outrageous, we have the right to eat food the way our Creator made it and not have forced food treatment!! PLEASE Don't do it !!!!!!!!!!!!!!Thank you!!
***I am totally AGAINST the pasteurization and/or the irradiation of organic green
foods. The process of pasteurization totally destroys the living enzymes that are in the greens and int the process makes them a "dead" food. This makes our food
supply more nutrient deprived and toxic. I want the agri-business corporations
to take responsibility and use more hygienic handling practices and more prudent
shipping methods, even if it costs them a little more, rather than passing the
burden on to myself in the form of toxic, devitalized food devoid of most of its
nutritional value. Enough is enough!
*** Don't kill our greens. Pasteurization (irradiation) will kill all the nutrients. How about making the agri-business corporations take responsibility and use more hygienic handling practices and more prudent shipping methods, even if it costs them a little more, rather than passing the burden on to the consumer in the form of toxic, devitalized food devoid of most of its nutritional value. Enough is enough!
*** This email is to voice my strongest opinion in favor of the non-irradiation of green
produce. The integrity of produce handling can be better served by better handling
from the farmer to our table without rendering it nutritionally useless by the act of irradiating. The handling can and should be monitored more closely for proper handling and the costs absorbed accordingly.
It is a great sadness to the US and to the world to continue to destroy a vital food supply that we count on for our vital nutrition. I respectfully request you
reconsider this atrocious action and leave our produce as nature intended--non-o-
irradiated, alive and healthful. Thank you Kathy Inigarida
***I respectfully urge you NOT to mandate irradiation of leafy green vegetables [or any fruits or vegetables].
Instead, please mandate that agri-business corporations use more hygienic
handling practices and more prudent shipping methods, even if it costs them a
little more and they must pass those costs onto us, the consumers. Please do not
pass the burden on to us in the form of toxic, devitalized food devoid of most
of its nutritional value. Many thanks.
***The real issue here is that this regulation of leafy greens could lead to the ability of the government agencies to require pasteurization and/or irradiation of these foods.
What does this mean to you? You would be no longer able to purchase a whole,
raw, organic, non modified food. What is wrong with pasteurization or irradiation? These processes destroy the natural enzymes, vitamin and mineral content in the foods and often times incorporate the use of dangerous chemicals or processes. If these foods are regulated then you no longer will have a choice to eat naturally.
If the USDA feels that it needs to address the issue of possible food born illness
and/or bacteria in these foods then they should do so by routine inspection of the
processing facilities and possibly require a warning label on the packaging stating the above concern. AFTER ALL THE USDA DOES NOT REQUIRE WARNINGS
ON THE PACKAGING OF THE HAZARDS OF PASTEURIZATION, IRRADIATION, GENETICALLY MODIFIED FOODS, STEROID AND HORMONAL ADDITIVES AND OF COURSE THE EVER CONTROVERSIAL PRESERVATIVES, COLORINGS AND ARTIFICIAL FLAVORS, DO THEY?
STAND UP FOR YOUR RIGHT TO PURCHASE AND CONSUME FRESH, ORGANIC AND/OR RAW FOODS WITH OUT INTERFERENCE FROM ANY AGENCY WHICH COULD REQUIRE THESE FOODS TO BE ALTERED IN ANY WAY FROM THEIR NATURAL MOST HEALTHY STATE!
It is your health and the health of your children, retain control of your right to eat healthfully and decide for yourself.
***I strongly oppose the pasteurization of green produce particularly products sold as organic or natural.
I say give the consumer the choice. People who buy certified organic or natural
products are careful about what they eat. Allow the distributors of these
products to choose not to use pasteurization or irradiation and label there
products so that the consumer will know they were not chemically treated or
irradiated to achieve pasteurization. There is only a slight chance that
someone will accidentally buy these items as they usually cost significantly
more than non-organic produce. If someone wants produce that is organic or
natural they should be able to buy, unadulterated by chemical or radioactive
processes. Again, the people who buy these types of products are careful about
they're food. Let them choose to clean there own produce or buy treated produce
and see how informed consumers decide. Let the market do it's job. Let the
market decide.
***The proposed pasteurization/irradiation of all greens is a diabolic plot to rob the populace of its inherent right to eat nutritional food. You know right well that exposing the produce to any level of heat or radiation is tantamount to killing the food and thereby causing irreparable harm to those who eat it. In essence, you are proposing the slaughter of our food supply as the means to slaughter millions of innocent lives. If you approve this regulation, you will answer to YHVH Almighty for your unrighteous actions.
***The agri-business corporations need to take responsibility and use more hygienic
handling practices and more prudent shipping methods, even if it costs them a
little more, rather than passing the burden on to consumers in the form of toxic,
devitalized food devoid of most of its nutritional value. Enough is enough! This
practice of irradiation would be unhealthy, counter-intuitive to what we know is
good for the environment and good for consumer health.
*** the irradiation of any vegetables is irresponsible and unnecessary. this process will just create more problems and will make the items in question take more time to market and be riskier. We want you to know we want the agri-business corporations to take responsibility and use more hygienic handling practices and more prudent shipping methods, even if it costs them a little more, rather than passing the burden on to you in the form of toxic, devitalized food devoid of most of its nutritional value.
***Hello, I am writing to comment about the proposed rules that would require the irradiation of salad greens. This rule is counterproductive and would in addition to degrading our environment and lowering the nutritional value of
salads, result in a huge financial loss to the small market farms throughout our
country. I urge you to take real precautions such as discouraging the
centralization of our food system and allowing the contamination of packing
water with manure from factory feed lots. Please review comments on this issue
submitted by organic farm advocacy groups such as the Cornucopia institute and
NOFA, and refrain from enacting any draconian regulations. Sincerely, Ryan
Voiland -certified organic farmer from MA.
***I urge you to drop this bill immediately. The health and wellness of our nation is in jeopardy because of the poor nutritional status of most American Citizens. Interfering the the fresh fruits and vegetable through pasteurization or irradiation will only make this situation worse. The best nutrition for people are fresh fruits and vegetable in their natural state with all enzymes and nutrients intact. Through
pasteurization and irradiation all nutritional benefits will be eliminated from fresh produce. I urge you to drop this bill. Please protect our precious food supply by not interfering in the process of nature. Through proper farming techniques, leafy greens are very safe and do not require any unnatural methods to sanitize them. People have lived for a very long time without sanitized leafy greens. I appreciate you taking the time to read my comments and I pray you make the correct decision.
***Salads, as everyone knows, are healthy dishes. Why? Because they are based on fresh, leafy greens. If these greens are cooked to pasteurization temperatures - - or radiated -- they lose their living enzymes as well as their freshness.
Our government needs to mandate and enforce habits of cleanliness, whether in
the field, the dairy or the slaughterhouse. Neither pasteurization nor irradiation are proper solutions to careless growing, harvesting, and processing practices. Even if they're cooked by pasteurization, feces, dirt and bacteria, etc. are not appealing additions to our food supply.
Rather than masking the problems with this unwise proposed regulation, our
government needs to take responsibility by implementing and enforcing standards
of food purity.
*** Re: Docket ID AMS-FV-07-0090 Federal Register pages 56678-56680, vol. 72, no. 192, October 4, 2007 Dear USDA Agriculture Marketing Service, Thank you for the opportunity to comment on the Advance Notice of Proposed Rulemaking for a Marketing Agreement for Leafy Greens. I am concerned with the proposed rulemaking for several reasons.
First, I believe that neither a Marketing Agreement nor a Marketing Order are
appropriate models when seeking to protect food safety on a national scale. Both
models would allow a small board of processors and handlers to set the rules for
all farms in the nation who wish to sell their vegetables to processors. It puts
disproportionate power in the hands of large operations and corporations, who
would most likely be represented on these boards. This board would be given the
government-sanctioned authority to dictate the growing practices for all other
farms?large or small?in the nation, which I believe to be an inappropriate model
and level of authority. I am also concerned that appropriate guidelines, suitable for small as well as large farms, have not yet been developed. I encourage the USDA to delay the implementation of federal standards until scientifically proven methods for reducing E. coli 0157 contamination have been demonstrated. The California Leafy Green Marketing Agreement (LGMA) guidelines have already been
implicated in two recalls, showing that more research is needed before a set of
uniform standards can be required throughout the nation. Furthermore, federal
regulations would discriminate against many farmers who employ organic farming
practices and farmers who promote biodiversity on farms, as has been the
experience with the California guidelines. The adoption of such rules on a national level would harm the environment, and more environmentally friendly guidelines must be developed if they are to be mandated nationally. I would also like to note that the risk of E. coli 0157 contamination comes predominantly from ?fresh cut? lettuce and spinach?the prewashed, precut bags of greens that have recently become so popular. Therefore, even if the USDA were to require standardized growing practices, it should apply only to large-scale suppliers of ?fresh-cut? bags of leafy greens, and exclude whole leafy greens that have never been implicated in an E. coli 0157 outbreak, such as kale, arugula, and chard. A one-size-fits-all approach is totally inappropriate in addressing this important health and environmental rulemaking proposal. If federal guidelines were to be enacted, there should be an exemption based on scale?small-scale farmers should not have to follow the same rules as large-scale operations that have been responsible for past widespread contamination. Moreover, exemptions should exist for traditional farmers selling locally and for farmers with organic certification. Although no fresh food production is risk free, the smaller operations, with hands-on management, pose an infinitely smaller risk to the nation?s citizenry. Finally, I oppose the proposed Marketing Agreement because it would likely be costly and overly burdensome to small- and medium-scale growers and could potentially drive these farmers out of business. As a consumer of leafy greens and a supporter of environmentally sustainable, local food systems, I urge the USDA to not support one-size-fits-all requirements that would dictate to farmers how to grow their vegetables, especially when such guidelines are not evidence based and are written by and for large-scale operations?farms, that based on past experience, might very well need additional regulatory oversight. Thank you for your consideration.
Could irradiation reduce the enzyme content of the leafy greens? I would think so.
Sincerely, Amy Storbakken
*** Please do not allow the irradiation or pasteurization of leafy greens. We need nutrients in our food. Let's have healthy citizens in a healthy country for a healthy future.
***This is a terrible idea! Irradiation (referred to here as "pasteurization") destroys
more than pathogens. Please leave our food alone! Especially organic food that
people go to such lengths to keep pure! E-coli comes from animals, not greens.
If you want to regulate something, keep animal feces away from fields planted with
greens, don't destroy the nutritive value of the greens that many of us depend on
for our food!
There is always a risk of food contamination. It can't be completely prevented.
Don't reduce the quality of our food in an attempt to accomplish something that
cannot be done!
PLEASE DON'T DO THIS!

***Irradiation of any food is not a good idea. Irradiation robs food of its vital nutrients. Washing one's before and after handling food that has also been
washed, is the best and only real safeguard for vegetables and fruits.
***
I am concerned with the proposed rulemaking for several reasons. First, I have
healed many health problems by consuming a strict raw, organic food diet. It has
truly been a miracle for me to detoxify my body with natural food after years of
consuming a standard American diet. No pills or treatments have had the power of
to affect my health like a raw food diet has. I need to be able to obtain these foods because I personally have experienced the miraculous effect of pure untampered food as God gave us.
The risk of E. coli 0157 contamination comes predominantly from ?fresh cut?
lettuce and spinach? the pre-washed, pre-cut bags of greens that have recently
become so popular. Therefore, even if the USDA were to require standardized
growing practices, it should apply only to large-scale suppliers of ?fresh-cut? bags of leafy greens, and exclude whole leafy greens that have never been implicated in an E. coli 0157 outbreak, such as kale, arugula, and chard. A one-size-fits-all approach is totally inappropriate in addressing this important health and environmental rulemaking proposal. I consume these to maintain my restored health, and I need to be able to buy organic vegetables that have not been irradiated, so I strongly believe that organic should exclude irradiation. Also, any consumable item that has been irradiated should by law have to indicate that on its label..
If federal guidelines were to be enacted, there should be an exemption based on
scale?small-scale farmers should not have to follow the same rules as large-
scale operations that have been responsible for past widespread contamination.
Moreover, exemptions should exist for traditional farmers selling locally and for
farmers with organic certification. Although no fresh food production is risk free, the smaller operations, with hands-on management, pose an infinitely smaller risk to the nation?s citizenry.
Finally, I oppose the proposed Marketing Agreement because it would likely be
costly and overly burdensome to small- and medium-scale growers and could
potentially drive these farmers out of business. As a daily consumer of llarge
quantities of raw leafy greens and a supporter of environmentally sustainable, local food systems, I urge the USDA to not support one-size-fits-all requirements that would dictate to farmers how to grow their vegetables, especially when such
guidelines are not evidence based and are written by and for large-scale
operations?farms, that based on past experience, might very well need additional
regulatory oversight.
Sincerely, Hope Lucky
*** Please reconsider your plan to subject vegetables to irradiation. Have you researched to see if this will kill the healthy nutrients that are essential to keeping and maintaining healthy humans? If you have done studies, publish your results so we can understand exactly how the irradiation will affect our food source. I consider this a serious step in devaluing and perhaps destroying our already "over processed" food supply. Thank you for your consideration.
***PCRM has 5,000 medical doctors and 100,000 lay people who are opposed to the irradiation of raw greens. If sheep are not allowed to be pastured in the fields in which the greens are later grown, or if cattle's holding pens are not upstream from the fields, there would be no problem with contamination. Irradiation destroys the very factors that people need for cell regeneration from live greens. The electricity in live foods is the very thing that keeps one's heart pumping, the diaphragm flexible, the nerves and muscles firing and flexing. When we eat nothing but cooked foods, we degenerate. When we eat living foods that have not been irradiated or sprayed with poisons, we are able to continuously rebuild our immune systems.in the constant battle against illness. Think of the children and grandchildren who need to have their greens untampered with irradiation. Reduce the pollutants. Have sufficient bathrooms and washrooms for the people who pick and gloves for hygienic sorting, rollers and conveyor belts minus the fiberglass and asbestos, and boxing/packing materials that are not plastic, and we, the people, will get healthier and won't have to worry about e. coli or other fecal bacterial contamination. People are getting well with raw foods. People are dying eating irradiated and sprayed with insecticide and pesticide foods. Be strong and vote for pure foods, not irradiated or poisoned (like with the almond vote) foods..
***
I am making a comment about this because I am a raw foodist and only eat food
that has not been heated above 118 degrees. I do not want leafy greens to be
pasteurized because then I would not be able to purchase these any longer. I will
have to find another source of greens that have not been pasteurized or learn how
to grow my own food. Pasteurization and irradiation of foods may be better for
large corporations that want an easy way to make their food sanitary but it is not
better for the American people!!!
*** Docket #AMS-FV-07-0090. Docket ID AMS-FV-07-0090-0001. Federal Register/Vol. 72, No 192/ Thursday, October 4, 2007 page no. 56678, 56679, 56680. Food Safety Regulations for Leafy Greens Under the Agricultural Marketing Agreement Act of 1937 (AMAA). I am a heavy consumer of fresh raw leafy greens. Since fresh raw fruits and leafy greens have been my diet
for 7 years, I have enjoyed vibrant health and far more energy throughout the day. I have noticed an alertness especially upon waking up and after lunch. When I was on a diet of pasteurized and irradiated foods, I would wake up drowsy and be exhausted after lunch. Friends who have often been exhausted have asked me what I was doing to feel so well. I have always said I've increased my percentage of fresh raw fruits and leafy greens in my diet. After they checked their
own urine pH and found it more acidic, without fail, each person adding a greater percentage of raw leafy greens to their diet brought their urine pH to a more alkaline state, and they all felt a difference of more vibrancy. It is of the utmost importance for raw leafy greens to be available for the general public to purchase and consume. Proposing pasteurization or irradiation would
change the basic chemical makeup of leafy greens. Leafy greens would then have far less nutritional value undercutting the ability for the leafy greens to support vibrant human life.
*** Leafy green vegetables are extremely important to my diet. In fact, fresh organic leafy green vegetables are saving my life!
I am NOT in favor of packers, processors, shippers, and marketers
(collectively referred to as handlers) using pasteurization,
irradiation and other forms of unnatural processing to maintain the
quality of their products and reduce the risk of pathogenic
contamination during the production and handling of leafy greens.
I want the agri-business corporations to take responsibility and use
more hygienic handling practices and more prudent shipping methods,
even if it costs them a little more, rather than passing the burden
on to me in the form of toxic, devitalized food devoid of most of its
nutritional value.
*** I can't believe how paranoid you guys are getting!!!!! Pasteurizing leafy greens????? What on earth is going on????!!!!! Leave my leafy greens alone!!! I want them FRESH, not tampered with and KILLED before I get them on my plate!!!! First almonds, now leafy greens, this is getting way OUT OF HAND.
I have my right to choose what I eat and how I eat it. I prefer RAW
UNADULTERATED UNPASTEURIZED FRESH FROM THE FIELD GREENS WITH ALL ITS NUTRIENTS
IN TACT !!!!
So PLEASE Get rid of this stupid proposed regulation, NOW !!! AMS-FV-07-0090
IRRADIATION IS TOXIC. !! Stop tampering with my ability to get healthy foods!
Then again, Let's poison all Americans, why don't we, will save on the amount of
wars we have to fight to defend them..... Geez, you guys in Govt,
WAKE UP!!!!!!!!!!!!!!!!! LEAVE MY LEAFY GREENS FRESH AND HEALTHY !!!!
*** Re: AMS-FV-07-0090 As a Ph.D. biochemist and ardent cook, I oppose irradiation or "pasteurization" of all greens because it decreased the availability of nutrients in our food. I passionately believe in supporting small local organic farms and farmers markets; irradiation requirements would put them out of business.
Sincerely, Linda Jean Shepherd, Ph.D.
***I, as a tax paying American citizen, have the right to food in its natural state. "pasteurized" greens are NOT acceptable.
The fact that you plan on including Organic is even more unacceptable.
This whole concept is totally ridiculous and so unnecessary. Do you wonder why
this country has such a health problem? It is because of the way so many people
stuff themselves with crap food - food that has been chemicalized, "pasteurized"
(your word for irradiation) - and processed to the point where it becomes poison
rather than nutrition.
You are insulting those of us who know better, and have chosen to eat food in its
raw and NATURAL state. You are insulting those of us who choose to be healthy.
I demand that you do not move forward in poisoning the food supply.
DO NOT ENACT THIS BILL Docket ID AMS-FV-07-0090 Docket Title Food Safety Regulations for Leafy Greens Under the Agricultural Marketing Agreement Act of 1937 (AMAA) Document ID AMS-FV-07-0090-0001 Document Title Handling Regulations for Leafy Greens Under the Agricultural Marketing Agreement Act of 1937
***As a longtime consumer of locally grown organic leafy greens, I feel that regulation should be handled on a local basis.
The program's handling regulations should specifically address companies that
are distributing greens nationally since any contamination of their greens has the
potential to affect a much larger population.
Large growing and processing operations that are located within watershed areas
that include stockyards, meat processing plants and other sources of chemical
and bacterial toxins is a practice that should raise a red flag at the USDA, and
those companies should merit close scrutiny. Regulation should take place at
the beginning of the production cycle, starting with where the farms and packing
plants are located, rather than the final packing stage. It just makes better sense.
Ultimately, food supply issues such as the recent e.coli contamination cannot be
controlled solely by additional rules and regulation. There must be a common-
sense approach to production practices that is realistically enforceable, and the
most important way for the USDA to protect the consumer is by requiring truth in
labeling. If the consumer knows the conditions under which food is produced, if
the label "ORGANICALLY GROWN" could be trusted to ensure a safe growing
practices, it would enable consumers to make good decisions to protect
themselves. Without truthful labels and adequate information, consumers will
continue to be at risk.
I protect my family by buying locally grown produce directly from the farmers at
the farmer's market as much as I can. These farmers need the support of the
USDA, not regulations that would require irradiation and chemical treatment,
practices which are in conflict with healthy and sustainable farming practices.
Thank you.
*** As a longtime consumer of locally grown organic leafy greens, I feel that regulation should be handled on a local basis.
The program's handling regulations should specifically address companies that
are distributing greens nationally since any contamination of their greens has
the potential to affect a much larger population.
Large growing and processing operations that are located within watershed areas
that include stockyards, meat processing plants and other sources of chemical
and bacterial toxins is a practice that should raise a red flag at the USDA, and
those companies should merit close scrutiny. Regulation should take place at
the beginning of the production cycle, starting with where the farms and packing
plants are located, rather than the final packing stage. It just makes better
sense.
Ultimately, food supply issues such as the recent e.coli contamination cannot be
controlled by additional rules and regulation. There must be a common-sense
approach to production practices that is realistically enforceable, and the most
important way for the USDA to protect the consumer is by requiring truth in
labeling. If the consumer knows the conditions under which food is produced, if
the label "ORGANICALLY GROWN" could be trusted to ensure a safe growing
practices, it would enable consumers to make good decisions to protect
themselves. Without truthful labels and adequate information, consumers will
continue to be at risk.
I protect my family by buying locally grown produce directly from the farmers at
the farmer's market as much as I can. These farmers need the support of the
USDA, not regulations that would require irradiation of chemical treatment,
practices which are in conflict with healthy and sustainable farming practices.
Thank you.
Sarah Allen
*** Please vote NO on the irradiation of leafy vegetables as that will destroy any nutrients that may be left in them! It makes a lot more sense to have the agri-business corporations take responsibility and use more hygienic handling practices and more prudent shipping methods, even if it costs them a little more, rather than passing the burden on to Americans in the form of toxic, devitalized food devoid of most of its nutritional value.
It would be nice to see our govn't working for the people for a change instead of
the agri-business corporations.
Thanks so much for your time & consideration!
***Docket ID AMS-FV-07-0090
Docket Title Food Safety Regulations for Leafy Greens Under the Agricultural
Marketing Agreement Act of 1937 (AMAA) Document ID AMS-FV-07-0090-0001
Document Title Handling Regulations for Leafy Greens Under the Agricultural
Marketing Agreement Act of 1937 Date: December 01, 2007
I vehemently oppose using irradiation or any method or process that will kill
the enzymes and nutrients in my food.
This is once again the case where the corporate dollar is more important than
citizen nutrition. FORCE the corporations, farms and dairies to be responsible
by cleaning up their growing, processing, plants and facilities. Don't take
away my nutrition for corporate irresponsibility and laziness.
I am, and twelve members of my family are, furious with the proposal to
irradiate, and we vow to fight irradiation of our food, along with CODEX, every
step of the way.Sincerely, The Turner Family
***As a consumer of leafy greens I would like to see the growers being responsible for the cleanliness of their product. They need to use more hygienic handling practices to ensure safety for the consumer even if it costs them more and raises the price at the store. Please do not require the irradiation or pasteurization of leafy greens! It will leave the buyer with food that is devoid of most of its nutritional value. Consumers also need to be given a choice. Irradiated and/or pasteurized foods need to be labeled clearly!
*** I very much object to using pasteurization and/or irradiation to treat leafy greens because this will significantly reduce the vitality/health benefits of such foods. Raw live foods are very helpful in reversing a number of chronic systemic ailments in our society that have reached epidemic proportions. I believe that pateurization and/or irradiation of these living foods will do more harm than good. AMS-FV-07-0090-0001
*** Re: Docket ID AMS-FV-07-0090 Federal Register pages 56678-56680, vol. 72, no. 192, October 4, 2007 Dear USDA Agriculture Marketing Service,
Thank you for the opportunity to comment on the Advance Notice of Proposed
Rulemaking for a Marketing Agreement for Leafy Greens. I am concerned with the
proposed rulemaking for several reasons.
First, I believe that neither a Marketing Agreement nor a Marketing Order are
appropriate models when seeking to protect food safety on a national scale. Both
models would allow a small board of processors and handlers to set the rules for
all farms in the nation who wish to sell their vegetables to processors. It puts
disproportionate power in the hands of large operations and corporations, who
would most likely be represented on these boards. This board would be given the
government-sanctioned authority to dictate the growing practices for all other
farms?large or small?in the nation, which I believe to be an inappropriate model
and level of authority.
I am also concerned that appropriate guidelines, suitable for small as well as
large farms, have not yet been developed. I encourage the USDA to delay the
implementation of federal standards until scientifically proven methods for
reducing E. coli 0157 contamination have been demonstrated. The California
Leafy Green Marketing Agreement (LGMA) guidelines have already been implicated
in two recalls, showing that more research is needed before a set of uniform
standards can be required throughout the nation.
Furthermore, federal regulations would discriminate against many farmers who
employ organic farming practices and farmers who promote biodiversity on farms,
as has been the experience with the California guidelines. The adoption of such
rules on a national level would harm the environment, and more environmentally
friendly guidelines must be developed if they are to be mandated nationally.
I would also like to note that the risk of E. coli 0157 contamination comes
predominantly from ?fresh cut? lettuce and spinach?the pre-washed, pre-cut bags
of greens that have recently become so popular. Therefore, even if the USDA were
to require standardized growing practices, it should apply only to large-scale
suppliers of ?fresh-cut? bags of leafy greens, and exclude whole leafy greens
that have never been implicated in an E. coli 0157 outbreak, such as kale,
arugula, and chard. A one-size-fits-all approach is totally inappropriate in
addressing this important health and environmental rulemaking proposal.
If federal guidelines were to be enacted, there should be an exemption based on
scale?small-scale farmers should not have to follow the same rules as
large-scale operations that have been responsible for past widespread
contamination. Moreover, exemptions should exist for traditional farmers selling
locally and for farmers with organic certification. Although no fresh food
production is risk free, the smaller operations, with hands-on management, pose
an infinitely smaller risk to the nation?s citizenry.
Additionally, I oppose the proposed Marketing Agreement because it would likely
be costly and overly burdensome to small- and medium-scale growers and could
potentially drive these farmers out of business. As a consumer of leafy greens
and a supporter of environmentally sustainable, local food systems, I urge the
USDA to not support one-size-fits-all requirements that would dictate to farmers
how to grow their vegetables, especially when such guidelines are not evidence
based and are written by and for large-scale operations?farms, that based on
past experience, might very well need additional regulatory oversight.
Finally, I oppose the notion that pasteurizing or dousing edible plants with
chemicals or irradiation is somehow SAFER than the occasional outbreak of
something like E. coli. It just absolutely boggles my mind that someone would
think that chemicals/irradiation = safety. There is plenty of research to
demonstrate that irradiation/chemicals cause great harm to a human (or animal)
body. A better solution would be to work with factory or large scale farms to
help them utilize more humane and more ecologically sound farming/husbandry
practices. Factory farming was responsible for the E.coli on the spinach
outbreak. Therefore, instead of killing the plants that people may eat, work at
eliminating the source of the "safety" problem by looking at factory farms.
Thank you for your consideration. Sincerely, Willow Aureala, Ph.D.
***I want the agri-business corporations to take responsibility and use more hygienic handling practices and more prudent shipping methods, even if it costs them a little more, rather than passing the burden on to me in the form of toxic, devitalized food devoid of most of its nutritional value. It is hard to believe that your government representatives know so little about food and food value. Have any of them studied nutrition and the effects of
chemical fertilization and spraying and irradiation or 'pasteurizing'. This will mean giving us, the public, foods that have little or no food value, which will inevitably lead to more illness and allergies.
You must not let this bill pass. We who consume a raw diet request/ demand
the government not to alter our fresh, naturally grown fruits and vegetable. Please leave it as the creator meant it to be whole and unaltered for perfect health. Thank you. Donna Harcos
*** Please do not rush through regulations requiring the "pasteurization" of greens as this is surely a euphemism for irradiation, which is an extremely unhealthy thing to do with our most natural and
healthful foods. This is not something to rush through the legislature without adequate public comment, nor is it something to require without time for small farmers to properly understand what is being requested of them. Surely it makes more sense to give everyone a chance to propose better ideas for ensuring the safety of America's greens, and pushing legislation for "pasteurization" of greens forward is NOT the answer. Until many questions are resolved and all
possible solutions carefully considered... Just say "NO!" to pasteurization!
Sincerely, Cynthia S. Larson
***As a longtime consumer of locally grown organic leafy greens, I feel that regulation should be handled on a local basis.
The program's handling regulations should specifically address companies that
are distributing greens nationally since any contamination of their greens has
the potential to affect a much larger population.
Large growing and processing operations that are located within watershed areas
that include stockyards, meat processing plants and other sources of chemical
and bacterial toxins is a practice that should raise a red flag at the USDA, and
those companies should merit close scrutiny. Regulation should take place at
the beginning of the production cycle, starting with where the farms and packing
plants are located, rather than the final packing stage. It just makes better
sense.
Ultimately, food supply issues such as the recent e.coli contamination cannot be
controlled by additional rules and regulation. There must be a common-sense
approach to production practices that is realistically enforceable, and the most
important way for the USDA to protect the consumer is by requiring truth in
labeling. If the consumer knows the conditions under which food is produced, if
the label "ORGANICALLY GROWN" could be trusted to ensure a safe growing
practices, it would enable consumers to make good decisions to protect
themselves. Without truthful labels and adequate information, consumers will
continue to be at risk.
I protect my family by buying locally grown produce directly from the farmers at
the farmer's market as much as I can. These farmers need the support of the
USDA, not regulations that would require irradiation of chemical treatment,
practices which are in conflict with healthy and sustainable farming practices.
Thank you.
*** This proposal is for federal regulations to mandate the 'pasteurization' of all greens. And as bad as that sounds, it gets worse: the FDA has started using the word 'pasteurize' as a euphemism or cover for what they really are up to, which is irradiation. I've seen this coming (they've already mandated 'pasteurizing' almonds-- burning them with carcinogenic, banned rocket fuel... yes, really!)-- but they've sprung it on us, revealing their plan only recently, and allowing only till Monday, Dec. 3 for public comment. (In the past, the FDA had comment periods of several weeks or even months. This is obscene!
Almonds in September 2007; all greens (including organic) in the near future;
what's next? Our food supply is becoming ever more nutrient-deprived and/or toxic.
Look at the alarming increases in Cancer, Diabetes, etc that have plagued us in
recent years, not to mention the arrival of HIV/AIDS in the last 25 years. When will the US Government stop destroying our planet, and our ability to purchase SAFE, NON-TOXIC ORGANIC FOODS?
We do not want government intrusion into our freedom of choice any more - we
have lost enough of what our nation was founded upon. STOP THIS INSANITY
NOW.
***Consumer Comments on Food Irradiation