There are over 700 produce farms in the State of Alaska, over 40 farmers’ markets, and dozens
of very successful school garden and Farm-to-School programs which supply local produce to
Alaska schools and institutions. Alternative growing methods (high tunnels, hydroponics, and
aquaculture) and indoor growing facilities are increasingly common in Alaska, especially in
remote areas of the state. Food security is an important issue, as Alaska would have only a few
days food supply on hand in the event of disruption of the supply chain. Local “food hubs”,
community supported agriculture, co-ops, and other networks are making it simpler for farmers
to distribute their crops to consumers.
As produce production in Alaska continues to grow, and as the implementation of the Produce
Safety Rule rolls out to smaller farms, the need for outreach, education, training, and technical
assistance will increase. Additionally, the with the increased use of new growing methods like
indoor, stacked hydroponic systems, the number of “farms” that fall under the most extensive
application of the Produce Safety Rule will grow.
Under AS 17.20, the Alaska Food Drug, and Cosmetic Act, the commissioner of the Alaska
Department of Environmental Conservation (ADEC) has broad authority over food offered to
the public, inspection of food products, food labeling, and the training, testing, and certification
of individuals that handle or prepare food. Currently, in addition to ADEC’s Food Safety and
Sanitation program, the Office of the State Veterinarian (OSV) provides regulatory oversight
and inspection for milk, milk products, frozen desserts, and reindeer slaughter and processing,
and the Environmental Health Lab assists both programs with analyses and data management.
Staff at the OSV are uniquely qualified to plan for and conduct the required training, outreach,
and inspection components of a new Produce Safety Program. The State Veterinarian and
Assistant State Veterinarian have, in addition to their Doctorates, advanced training in public
health, zoonotic diseases, and food science. The Assistant State Veterinarian has conducted
research on pathogenic Salmonella bacteria on alfalfa sprout seeds, an important topic in the
realm of food safety. Additionally, the Environmental Health Officer in the OSV has extensive
past experience as a USDA farm food safety auditor and educator, and has been active in the
rulemaking phase and implementation of the FSMA Produce Safety Rule since 2012 through the
Cornell Produce Safety Alliance (PSA). The OSV’s existing relationships with the agricultural
community in Alaska also lends itself to placing the program here.
The State of Alaska looks forward to working with FDA to continue our long-standing efforts of
maintaining and enhancing food safety for consumers throughout our great state, and we thank
FDA for the opportunity to partner on the implementation of this important new regulation.