to workmen’s safety, environmental concerns, consumer considera-
tions, and energy allocations. Because of these requirements,
enormous sums have been spent and invested by this industry in
recent years and at an accelerating annual rate. These non-produc-
tive capital demands compete with productivity and modernization
investments to such an extent that it now seems certain there will
continue to be substantial capacity abandonment without replace-
ment.
It was within the context of this economic environment that
officials of the Federal Food and Drug Administration conducted a
series of meetings with cannery representatives during the winter
1974-75 to advise there would be intensified surveillance of industry
sanitation practices in the following processing season.
It was made clear that a new emphasis for determining cannery
compliance with the agency’s prescribed good manufacturing
practices would be a microscopic search of finished products for the
detection of geotrichum mold. As is readily acknowledged by the
FDA, geotrichum is a totally harmless mold. Its spores are
omnipresent in the summertime atmosphere and its development is
favorably nurtured by fruit sugars and warm temperatures.
Obviously, this is a combination impossible to avoid in summer
season fruit canning operations, just as it is in household kitchens
where the mold also commonly appears.
Nevertheless, the agency representatives made it evident that if
this mold were detected in products obtained at the time of an
inspector’s visit, preceding production also could be examined to
determine if condemnation actions would apply to production not
personally observed by the inspector. Since applicable regulations
contain no tolerance for this mold, the effect of the agency’s
announcement was to mandate that a zero tolerance could be
enforced. It would be, of course, at the agency’s sole discretion.
I asked our technical services people to determine what, if
anything, could be done to assure compliance with enforcement of
zero tolerance requirements. Their response, confirmed by outside
scientific consultants, was that nothing could be done short of
limiting daily production intervals to periods that would be
economically impossible to maintain.
Finally, since it would be impossible to assure the complete
absence of geotrichum from canned fruits, our best strategy would
be to intensify cleaning operations. Thus it would seem evident to
inspectors that we were making an exaggerated effort to achieve
compliance. To do this required a hard-to-swallow decision: as
69