Further efforts are required, Mr. Richardson says, including organizing a pesticide- use reporting system, planning and funding integrated pest management (IPM) programs, placing risk communications under control of a group clearly oriented toward the recipients of the message, increasing funding for alternatives and research into safer chemicals, voluntary prohibitions or modifications of pesticide use and tougher accreditation for both testing laboratories and individual producers.
There are several levels of product recovery depending on severity:
A. Stock Recovery: The removal or correction of materials that have not left direct control of the producer/packer. This is considered an internal matter
and the FDA need not be notified.
B. Market Withdrawal: If the product has left producer/packer control, then withdrawal is from the marketplace. This is appropriate when consumption of the product is not considered a significant health hazard. This most commonly involves a minor violation or no violation that would be considered actionable by the FDA.
C. Recall: A voluntary program implemented by the affected industry. A recall involves products in violation of FDA administered laws. The FDA does not have statutory authority to mandate a recall, but can request federal courts to seize any product deemed harmful. Honey might be recalled if agricultural chemicals exceed a tolerance, or employer or employee negligence or a disgruntled employee results in product adulteration.
If a recall is instituted, a recommended plan of action includes:
A. Create a Recall Team: Depending on the size of the firm, individuals on the team might include a legal counsel, public relations person, in-house laboratory technician and/or a certified laboratory.
B. Develop a Recall Strategy: It is important during this step to define the problem based on answers to questions such as the extent of the health hazard, the risks to consumer and industry and the jurisdiction of the FDA. Based on heath hazard the recall could be designated as Class I (most hazardous) to Class III (least hazardous to health).
1. Determine Depth of Recall: Specify, in coordination with FDA, the level in the distribution chain from which products will be recalled; consumer level, retail level, wholesale level, or geographic location.
2. Develop methods to identify and retrieve contaminated honey. A testing program should be developed to identify contaminated product as well as an action plan to collect the product.
C. Recall Communications: This area includes notification of the FDA, then notifying the public and physically withdrawing product from the market. If considered hazardous enough, a public warning may also be issued. Finally, the FDA recommends a periodic status report be submitted.
A bibliography and sample press release concerning honey recall is also attached to the information as is a recommended honey sampling procedure and a list of laboratories providing analytical services. The packet of information is available from the National Honey Board (see address elsewhere in this issue). It would be advisable to have it on hand as a guide to handle any crisis arising out of honey contamination.
There is little doubt that costs in beekeeping are continuing to rise. Of special concern is treatment for Varroa mites which are considered absolutely necessary if a colony is to survive and infestation (see last month's issue of APIS for details). The analysis of the effects of these expenses, therefore, must become paramount for many beekeepers. To help in this endeavor, I have written IFAS Circular 722, A Study in Profitability for a Mid-sized Beekeeping Operation. Unfortunately, this publication is in short supply. Perhaps the best way to ensure obtaining a copy is through contacts at the local county Cooperative Extension Service office. It is available at both the Florida State University and University of Florida libararies. Some local libraries may also have it.
Hint for the Hive number 124, "Financial Statements and Ratios for Beekeeping Operations," also was published to help beekeepers better analyze their activities. It provides an outline allowing one to sift, select and file necessary information to make informed financial decisions. County extension offices have limited supplies. I can furnish one on request as well.
Malcolm T. Sanford
Bldg 970, Box 110620
University of Florida
Gainesville, FL 32611-0620
Phone (904) 392-1801, Ext. 143 FAX: 904-392-0190
http://www.ifas.ufl.edu/~entweb/apis/apis.htm
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