FDA issued a "Guidance" on Sprout Safety -
But don't let that stop you from voicing your opinion!
Keep Sending Comments!
Save Our Sprouts
This page gives you what you need to send comments to the FDA.
We also have a pre-written comment letter
which you can print, sign and send off - if you don't have the time to write your own.
Where to Send Comments:
Docket No. 99D-4488 and 99D-4489
Dockets Management Branch (HFA - 305),
5630 Fishers Lane, rm. 1061
Rockville, MD 20852
Subject line: Docket No. 99D-4488 and 99D-4489
These are the basic points for your letter:
As it Reads Now The Proposed Guidelines Will:
1) Put all Certified Organic Sprout Growers out of business.
2) Force all sprout growers to have in-house laboratories.
3) Not make sprouts safer.
4) Make the annual dumping of over 26 Million Gallons of Bleach OK.
5) Make it even harder to get good bacteria into your diet.
Tell the FDA that the New Guidelines Must:
1) Create a safe source of seed intended specifically for human consumption.
2) State that "Certified Organic Seed is considered an acceptable alternative approach to prevention of microbial hazards in sprouted seeds".
3) Create a government certification that labels seed grown for human consumption as such (i.e. Grade A Beef) and make it mandatory that sprout growers use that government certified seed and/or certified organic seed.
1. Certified Organic Seed is safe - No illness has ever been blamed on sprouts grown from Certified Organic Seed!
2. New guidelines must focus on creating a safe source of seed for non-organic (conventional) sprout growers.
3. FDA should use Certified Organic Seed Farmers to help develop guidelines for the conventional (non-organic) farming of seed for human consumption.
4. Even in the worst year(s) for sprouts (1995-96), they were only responsible for a fraction of a one percent of the annual foodborne illness in the US. This whole thing is way out of proportion. 93% of the annual foodborne illnesses in the US are traced to Meat, Poultry and Dairy (wealthy industries with plenty of lobbyists).
Here is the gist of the Guidance:
FDA is telling us that we MUST bleach our seed and that we MUST have an in-house lab to test for pathogens.
Very few growers can afford a lab so most will just close their doors. There will be NO Certified Organic Sprouts!
FDA knows that NO illness has ever been traced to Certified Organic seed.
"Certified Organic seed is the best starting point for sprout safety" says Jeff Davis, Chief Medical Officer of Wisconsin HFS (the Health Department)
The FDA must create a source of clean seed - seed intended for human consumption - to be used for sprouting.
FDA should hire Certified Organic seed farmers and processors to aid them in establishing guidelines which they can use to certify that seed produced for human consumption is safe. Conventional (non-organic) farmers will need to follow these guidelines in order to have their seed certified for human consumption before they can sell it to the lucrative sprout industry.
It is outrageous that the FDA is continuing to demand that sprout growers solve the problem of seed safety instead of putting that responsibility on the seed producers.
Human Beings (as well as other animals) need bacteria. Bacteria lives in our guts. Without it we are more susceptible to ailments. FDA has been making bacteria more rare in our food for years - unpasturized juice is now hard to find, they want sprouts bleached which kills all the bacteria and next on the list is irradiation of produce. As Jeff Davis, Chief Medical Officer at Wisconsin HFS says "We are dependent on commensal bacteria." Without healthy bacteria in our diets we will be sick!
It is hoped that sterilizing sprouting seeds with bleach kills all the bacteria. We now know - from the recent Wisconsin outbreak of salmonella, that that is not true. By shifting the population of bacteria so dramatically pathogens can grow unabated. It is a very dangerous way of achieving safety.
Read the complete text of the FDA Guidance
What Is the Sprout Industry Doing About This:
Commercial sprout growers need to stand up to the FDA and demand clean seed. The ISGA (International Sprout Growers Association) has been kissing the government's butt from the start. They never asked why the sprout industry was getting a disproportionate amount of attention for only a fraction of 1 percent of the annual cases of foodborne illness in the US. They tolerate the statement: "Incidence of foodborne illness caused by sprouts is increasing." Even though - contrary to what the FDA says - incidence of foodborne illness associated with sprouts has been declining for over 4 years.
They said yes to a level of bleach which is so toxic that the EPA would only approve it for one year (though they've extended it for a second year and FDA has told OLIN Chemical - the makers of the basic ingredient - calcium hypochlorite - used to make bleach - to apply to the government for permanent acceptance) while other forms of seed sterilization could be researched.
Now they are being told that they must all have laboratories in their sprouting facilities and that they must run over 30 tests on every batch of sprouts they produce. What's more, they must send out to a private lab (and wait 3 days for the results - while their sprouts age. And private labs are not at all an inexpensive proposition ) any tests that their lab reports as having ANY bacteria for identification. The ISGA knows that very few sprouters will be able to afford labs. Only a handful will survive and still they will be starting with dirty seed, bleaching it a level which currently is responsible for the dumping of the equivalent of not less then 26 million gallons of household bleach every year.
The ISGA has completely lost their way! The bulk of sprout growers were once passionate about sprouts. They produced a healthy product packed with good living organisms, vitamins, minerals, amino acids, protein, chlorophyll and antioxidants. The demand for natural, healthy foods grew and grew and their sprout passions turned into businesses. Now they are business people - not sprout people - and they think "Our product will be safe - we will bleach the seed and irradiate the sprouts" (ISGA board member). Sprout eaters do not want that product! The growers who believe that statement are willingly poising the planet for the sake of their "health food".
Sprout growers - Remember why you started sprouting and THEN start talking with the FDA! They work for you!
Download our Signage and Literature - get your local health food community involved!
Print Our Comment Letter
Read the complete text of the Guidance
Read a Brief History of the October, 1999 Salmonella Outbreak in Wisconsin as Seen From Our Perspective