In comments filed this week with the Food and Drug Administration, IDFA welcomed the agency's advance notice of proposed rulemaking for implementing the Sanitary Food Transportation Act of 2005. IDFA stressed the importance of a collaborative approach and offered to share the industry's substantial insight and experience to help develop appropriate standards and practices.
"The best rules and regulations are made not on the basis of absolute prohibitions, but through extensive collaboration between federal, state, local and industry partners which reflect all aspects of the products and packaging attributes and the totality of circumstances under which foods are transported," the comments said. "When the government and the private sector take the time to properly identify problems and work together to solve them, the results are superior."
The proposed rule is part of FDA's current focus on farm-to-table prevention of food safety hazards, which was a primary recommendation made in May by the federal Food Safety Working Group in its report to President Obama.
PMO Model to Follow
In the comments, IDFA addressed several of areas of concern that FDA raised in the notice, including temperature control during transport, sanitary practices and communications among partners in the transportation process. Noting that only one transportation-related incident in more than 30 years has involved dairy products, IDFA explained how industry and government came together to learn from the incident and adopted practices that prevent cross-contamination.
IDFA pointed to another collaborative effort, the Pasteurized Milk Ordinance, as a model of sanitation standards of excellence for milk and milk products. IDFA encouraged FDA to keep this model in mind when moving forward with transportation regulations.
Read the full comments here.
After evaluating the comments, which were due on Tuesday, FDA will coordinate with the U.S. Departments of Agriculture in the rulemaking process and propose specific regulations to implement the statute.
Earlier this year, FDA also issued "Guidance to the Industry on the Sanitary Transportation of Food" to provide interim recommendations while the agency proceeds with developing regulatory requirements.
Members with questions may contact Clay Detlefsen, IDFA vice president of regulatory affairs, at firstname.lastname@example.org.