• Reorder Point Formula: How to Calculate This Critical Inventory Metric

    • 04,Abr 2024
    • Posted By : humbertoamilcar
    which one of these would not be a factor in determining the reorder point?

    Some comments suggest that farms should only be exempt from testing as part of an agricultural water assessment if they can demonstrate that testing is not necessary for public health purposes. (Response 87) As discussed in response to comment 93, we are not establishing a specific testing frequency that farms are required to follow if testing their pre-harvest agricultural water as one part of an assessment. Rather, § 112.43(d)(3) provides flexibility for farms to use a sampling frequency that is scientifically valid and appropriate. This enables farms that test their pre-harvest agricultural water as part of an assessment under § 112.43(c)(4)(ii) to take into account conditions that are unique to their operations and practices when establishing appropriate sampling frequencies under § 112.43(d)(3). We discuss conditions that may be relevant to some CEA farms in response to comments 39, 40 and 46, which farms may consider in establishing an appropriate sampling frequency under § 112.43(d)(3).

    a. Accurate demand forecasting

    Other comments request clarity as to whether testing may be conducted at a lower frequency than that established in the 2015 produce safety final rule. A few comments suggest that one test per season prior to use would likely be sufficient for deep wells. Some comments request that FDA support research and education to help farms understand what sampling frequency is adequate. (Comment 50) One comment requests that FDA revise the requirements for agricultural water assessments in proposed § 112.43(a) to clarify that farms are only required to consider the degree of protection and/or adjacent and nearby land uses for surface water sources, and that only possible sources of contamination within the surface water’s drainage basin need to be considered.

    • (ii) Test the water pursuant to paragraph (d) of this section, consider the results as part of your assessment, and take appropriate action under paragraphs (c)(1), (2), or (3), or (c)(4)(i) of this section.
    • However, once you have a handle on the patterns of a product, you’re ready to start putting the variables together.
    • (Comment 117) A few comments note perceived inconsistencies as to whether the 4 days referenced in proposed § 112.45(b)(1)(ii) is intended to be a minimum interval between last direct application of agricultural water and harvest or a maximum interval.
    • Our primary estimates of annualized costs are approximately $17.5 million at a 3 percent discount rate and approximately $17.7 million at a 7 percent discount rate over 10 years.

    Reorder Point Formula: How to Calculate This Critical Inventory Metric

    These comments suggest that exempting water in these situations could be a gap in assessing the safety of the water. (Comment 34) Some comments voice concern that it will be difficult to prepare agricultural water assessments for farms that use multiple sources of water for pre-harvest activities. To the extent that comments are voicing concern over the scientific basis for the requirements for pre-harvest agricultural water assessments in § 112.43, comment 10 addresses those comments.

    G. General Overview of Changes in the Final Rule

    As occurrences such as these are important for farms to consider in complying with the requirements for pre-harvest agricultural water assessments, we decline to make the change suggested by the comment. Further, the knowledge and experiences gained since 2015 will be helpful in supporting successful implementation of the rule, including compliance with the requirements for pre-harvest agricultural water assessments. For example, we developed the 2015 produce safety final rule after considering, in part, that at the time of rulemaking, some farms had significant expertise in the area of food safety, and other farms had minimal knowledge in the area.

    Avoid stockouts:

    (Comment 110) With respect to the requirements in proposed § 112.45(a)(1), some comments seek clarity as to whether pre-harvest agricultural water for produce commodities other than sprouts needs to meet the water microbial quality criterion in § 112.44(a). (Comment 94) Some comments seek clarity around whether historical test results can be used to justify the safety of their agricultural water. Several comments encourage flexibility with regard to sampling frequency requirements by allowing inclusion of historic testing data in an assessment that may not have been conducted at the same level of frequency as discussed in the proposed rule. (Comment 82) Some comments suggest that proposed https://www.bookstime.com/ § 112.43(d) should specify that when testing pre-harvest agricultural water as one part of an assessment, sample collection should occur at specific times, such as “as close to harvest as reasonably possible,” to reduce the opportunity for farms to “cherry-pick” collecting samples at times when water quality is expected to be good. Farms that change crops frequently are likely aware of what commodities (or types of commodities) it is reasonably likely they may grow. This knowledge, along with practices such as grouping crops based on similarities in characteristics as discussed above, will assist farms in efficiently evaluating crop characteristics as part of their assessments.

    However, if a farm conveys that water through an open canal system prior to using it as pre-harvest agricultural water for non-sprout covered produce and it is reasonably likely that the quality of water will change prior to use of the water, the farm is not eligible for an exemption from the requirement to prepare an agricultural water assessment. The farm must consider the nature of the water source as part of their evaluation of the agricultural water system under § 112.43(a)(1). To the extent that some farms may be testing their pre-harvest agricultural water using the 2015 (or other) approach, we emphasize that nothing in this rule precludes them from continuing to do so, as long as they also comply with the requirements we are finalizing here, as applicable. (Response 9) As finalized with this rule, we are reorganizing subpart E in its entirety to group similar requirements. We note in particular that with this final rule, we are replacing §§ 112.44(b) and 112.46(b) in the 2015 produce safety final rule (microbial criteria and testing requirements, respectively, for pre-harvest agricultural water for covered produce other than sprouts) with requirements for written pre-harvest agricultural water assessments.

    which one of these would not be a factor in determining the reorder point? which one of these would not be a factor in determining the reorder point?

    Further, § 112.42(b) requires farms to regularly monitor each system, to the extent that it is under the farm’s control, to identify any conditions that are reasonably likely to introduce known or reasonably foreseeable hazards into or onto covered produce or food contact surfaces. If during such monitoring a farm identifies a condition that that is considered which one of these would not be a factor in determining the reorder point? a “significant change,” the farm must conduct a reassessment under § 112.43(e). See also response to comment 25, in which we discuss the relationship between inspections, maintenance, and pre-harvest agricultural water assessments. (Response 67) We recognize that CEA operations have unique considerations compared to more traditional outdoor growing operations.

    • (Comment 109) A few comments request clarity on what corrective measures would be appropriate for the example provided in the proposed rule in which a dead and decaying sheep results in water being not safe or not of adequate sanitary quality for its intended use.
    • It has further been suggested that the financial investment needed to develop a long-term profile for a water source that is only used every few years may not result in commensurate food safety benefits (Ref. 4).
    • The annual assessments employ a prevention-oriented quality-systems approach to food safety regulation that FDA has long used and successfully enforced across the highly diverse food industry that FDA regulates.
    • (Comment 125) Many comments note that there are currently no chemical treatment options approved by EPA for use in pre-harvest agricultural water against human pathogens, and express concerns that this may prohibit the use of water treatment as a corrective or mitigation measure until such products are approved.
    • By keeping a close eye on inventory levels and using the reorder point formula to guide reordering decisions, inventory managers can strike the perfect balance between too much and too little stock.
    • (Response 63) All agricultural water must be safe and of adequate sanitary quality for its intended use (§ 112.41), and we consider that evaluating crop characteristics, alongside other factors identified in § 112.43(a), as part of a farm’s agricultural water assessment will assist farms in determining whether this standard is met.
    • (Comment 6) Several comments seek clarity on what is expected of farms in terms of assessing water that is outside the scope of “agricultural water.” A few comments express concern that in some of the outbreaks cited in the 2021 agricultural water proposed rule, the water used to grow the produce would not have been subject to the requirements in the proposed rule.