fda presentation december 2009

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12/09/2009 Commodity Concern Connection LLC 1

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12/09/2009Commodity Concern Connection LLC 1

Commodity Concern Connection is a Richmond, VA based firm dedicated to the tracking and responsible sourcing of imported nut and agricultural commodities.

David Rosenthal (President, CEO) has been in the nut, seed and dehydrated fruit importing industry for more than twenty years, and has served as Chairman of the Nut and Agricultural Products Section of the Association of Food Industries.

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Commodity Concern Connection LLC

Recent major incidents include:

◦ Cashews from Vietnam found to contain a 520 Industrial glue (Krazy Glue)

◦ Chlorophenol found in cashews imported from India◦ “Pine Mouth” syndrome – ingesting certain imported

Asian pine nuts causes people to develop a foul, metallic taste which can linger for months. The cause has not yet been determined.

Tracking of source contamination is virtually impossible.

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Routine incidents include:

◦ Rejections due to presence of glass, metal, bandages, cigarette butts, hair, and other foreign material

◦ Microbial rejections are on the increase as companies implement more rigorous testing procedures.

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Visits to overseas facilities revealed serious food safety violations such as:

◦ Food processed on dirt floors◦ Workers sorting nuts with open sores on their hands ◦ Facilities open to insects, rodents, birds, monkeys,

domestic animals◦ Lack of hygiene facilities (hand washing, lavatory, etc.)◦ Filthy equipment

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Visits to overseas facilities revealed serious food safety violations such as:

◦ Lack of potable water for washing or food processing◦ No critical control points ◦ Improper or unsupervised use of chemical substances

such as insecticides, herbicides, disinfectants, etc.◦ Use of prison/forced labor in food processing◦ Unsupervised food processing in workers’ homes.

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Turkey – Apricots piled on dirty floor prior to bagging

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India: Workers sort cashews in a dirty, poorly lit facility on dirt floor, breeding bacteria and allowing for intrusion of insects and animals.

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Workers sort cashews using unsanitized containers (wicker baskets).

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Malaysia: Green pea processing machine. Machine is dirty, and facility is open to the outside, making premises accessible to rodents, insects, etc.

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Malaysia: Green pea processing area open to the outside

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These violations can result in:

◦ Bacterial contamination

◦ Chemical contamination

◦ Hazardous Foreign material

◦ Live Insect Infestation

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The current system is not designed for immediate traceback

Effective tracking systems are possible only with importing industry cooperation.

Tracking and responsible sourcing must go hand in hand.

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Industry specific navigators will be needed to help the FDA accomplish its goal of assuring that food consumed by the American public is safe and of high quality.

Partering with trusted industry organizations that share this goal can provide a cost effective solution.

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Contact Info:

David RosenthalCommodity Concern Connection LLC

Tel: [email protected]

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