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Comments at a Public Hearing of the Proposed Leafy Green Marketing Agreement

Allowing the leafy green industry to set and oversee its own safety standards, without public input, is undemocratic and contrary to key legal precedents in the regulatory field. A second major concern for Consumers Union is that, since participation in the marketing agreement is voluntary, not all leafy green growers and processors will be covered. Thirdly, we are concerned that the LGVMA may propose the use of a USDA certification mark to convey to consumers that leafy green products from those participating farms and processors are subject to Best Practices. Finally, Consumers Union is concerned that this proposal for a national marketing agreement to set safety standards for leafy greens, through a predominantly closed, industry-led process, is being considered at a time when Congress is in the midst of passing legislation that would require FDA to develop safety standards for leafy greens, through an open, public, and democratic process.