The California Leafy Greens Marketing Agreement (LGMA) has submitted its official comments on the Food Safety Modernization Act’s proposed Produce Safety Rule. The comments focus on a number of suggestions to strengthen the proposed rule, but the most important comment offered by the LGMA presents the U.S. Food and Drug Administration with a solution that would quickly allow it to regulate 90 percent of the leafy greens produced in the United States at no cost to the public. Read more about the LGMA’s comments here. The opinion piece by Daniel Cohen entitled, “FDA’s Proposed Produce Rule: A War on Farmers,” contained a great deal of misdirected information. Since some of it involved the California Leafy Greens Marketing Agreement (LGMA), we felt we should respond to the editors of Food Safety News. We also wanted to make an important point about the LGMA and its role in ensuring leafy greens producers are in compliance with proposed food-safety laws for produce. The LGMA was created in 2007 in the aftermath of the 2006 outbreak of E. coli associated with spinach. This effort was not a war on farmers, but a sincere effort by the farming community to prevent such a tragedy from happening again.  Thankfully, it hasn’t. Secondly, the people who created the LGMA did so very carefully, taking into consideration the impact such a program might have on farmers who may not be able to, or want to, participate. The LGMA is authorized under California law by the 1937 Agricultural Marketing Agreement Act and, as an agreement, membership is voluntary. Leafy greens handlers may sign on to the LGMA and agree to abide by its mandates. However, they do not have to do so. And every member is allowed to opt out of the program each year if they so choose. The LGMA is very proud to state there is an overwhelming commitment to this food-safety program within the California leafy greens community. LGMA members represent more than 99 percent of the leafy greens produced in the state. This means the vast majority of leafy greens producers in California have invited government auditors into their fields and farms to ensure they are following required food-safety practices. The system has, in fact, made leafy greens safer because the program focuses on putting food safety first. The mandatory government audits require 100-percent compliance with all food-safety checkpoints, and all citations must be corrected. This system drives continuous improvement and establishes a culture of food safety in which everyone from the top down is focused on prevention. Mr. Cohen is correct in his statement that not all foodborne illness outbreaks are linked to farming, but preventing outbreaks certainly starts with proper food safety on the farm. This week, the LGMA submitted its comments to FDA regarding the Food Safety Modernization Act’s proposed Produce Safety Rule. As part of these comments, LGMA is asking FDA to utilize our program to verify compliance with FSMA laws.  The LGMA requirements already meet or exceed the laws being proposed and audits are conducted by an independent, unbiased government agency. If FDA grants our request, more than 90 percent of the leafy greens grown in the U.S. could quickly comply with new federal food-safety laws. A large amount of support for this concept exits. A letter of support was recently issued to the FDA by a group of bipartisan Congressional representatives from California and Arizona. In addition, STOP Foodborne Illness, an advocacy group representing individuals impacted by foodborne illness, has high praise for our program. We truly believe the LGMA model is the best food-safety regulatory system because it is an effective, efficient partnership between industry and government. That said, the LGMA fully understands this system may not work for everyone. Our request to FDA is not that all farmers be regulated in a manner similar to our model, but we are asking that FDA recognize the LGMA system has worked for the California and Arizona leafy greens industry for six years. There is no reason for additional duplication or cost to ensure certified members of these programs are in compliance with new food-safety laws.