Noting the complexity of issues surrounding food safety and food defense, IDFA last week encouraged the Food and Drug Administration to proceed with its risk-based approach and to concentrate on developing guidance and training materials under the Food Protection Plan it released last November. In its comments, IDFA also recommended cooperating with foreign governments, embracing new technology and focusing the agency's limited resources on high-risk foods as keys to successful implementation.
The Food Protection Plan, a comprehensive initiative designed to bolster efforts to protect the nation's food supply, covers both imported and domestic products. It presents a strategy for protecting the U.S. food supply from both unintentional contamination and deliberate attack, and encompasses three core elements: prevention, intervention and response.
In its call for comments regarding the plan, FDA asked stakeholders to identify food safety best practices and the benefits of using them. In response, IDFA argued against the use of the phrase "best practices" in this context, because food safety issues do not lend themselves to simple solutions and practices, and few food industry best practices can be applied across the board to all companies.
"While frequently advocated and in vogue, meaningful best practices are elusive. There are no shortcuts that can substitute for a reasoned and learned approach," the comments state. "Guidance, when properly drafted, allows for issue spotting and the application of common sense, experience, knowledge and wisdom of those who know the facilities best – those who run and operate them."
IDFA also noted that the plan is missing two key components: the development and dissemination of employee training materials and defined efforts to enhance traceability. In the comments, IDFA encouraged FDA to make each of these activities a plan priority.
In addition, IDFA encouraged FDA to concentrate its limited resources on high-risk foods and to embrace new technologies. As an example, the comments mention that IDFA supports exploring innovative projects such as FDA's risk-based electronic screening system, PREDICT, which was pilot tested on seafood imports entering five Los Angeles-area ports. Using technology to share information between the private sector and foreign officials would also boost the plan's success rate, IDFA said.
The plan also proposed giving FDA legislative authority to issue a mandatory recall when voluntary recalls are not effective. In the comments, IDFA said it would not oppose the new authority as long as companies have been given "reasonable opportunity" to initiate a recall first.
To read the full comments, click here.
For more information, contact Clay Detlefsen, IDFA vice president of regulatory affairs, at firstname.lastname@example.org or 202-220-3554.