IDFA and nine other food trade associations met on Monday with senior officials of the Food and Drug Administration to discuss implementation aspects of the Food Safety Modernization Act. IDFA Vice President Clay Detlefsen urged them not to mandate finished product testing, saying it would impose considerable costs for companies without adding any public health benefit. He also called for a complete separation of food-safety and food-defense plans in the new regulations and asked FDA to grant an exemption for warehouses.
FDA invited the groups to participate in a listening session to gain a better understanding of industry's concerns and gather suggestions for enhancing the compliance success rate. Michael Taylor, FDA deputy commissioner for foods, attended the session along with senior leaders from the agency's food-safety implementation teams, including David Elder, chair, imports; Donald Kraemer, chair, preventive controls; and Daniel McChesney, vice chair, preventive controls. Several FDA officials representing consumer affairs, communications and external affairs also attended.
"This was a phenomenal opportunity for us to meet with FDA officials face to face and have a meaningful dialogue on the important issues that have surfaced thus far under the Food Safety Modernization Act," said Detlefsen, who represented IDFA at the session. "The session also was a great opportunity for FDA officials to refine efforts now underway before they issue proposed rules and guidance."
FDA Welcomes Industry Involvement
Taylor emphasized that FDA is committed to "early and active public engagement" to ensure that the agency's plans for implementation are well-informed, practical and effective. He indicated that involving industry would offer the best way to achieve high levels of compliance.
Detlefsen told officials that processing owners and operators - not FDA - are responsible for identifying potential hazards, implementing a process to control the plant environment, monitoring the effect of the controls and verifying that the process is working. He explained that testing and holding products from the market while waiting for results isn't feasible for fluid milk products. Pasteurization is the key to assuring the safety of milk and other dairy products, he said.
The officials agreed with Detlefsen that regulations for food-defense plans should be separate from food-safety plans. Including food-defense aspects in food-safety plans would make compliance too complex and costly since food-defense hazards are virtually limitless, Detlefsen said.
In addition, he highlighted a petition that IDFA and seven other associations filed with FDA last Friday asking the agency to exempt warehouse facilities that store packaged foods from compliance. (See "IDFA, Others Petition FDA for Warehouse Exemption.")
IDFA Submits Comments
IDFA will continue to work closely with FDA on all aspects of implementing the food safety legislation. To date, IDFA has submitted comments on three implementation aspects of the Food Safety Modernization Act and will submit a fourth set on finished product testing in August. FDA likely will release proposed rules on preventive controls and foreign supplier verification in October.
For background, read these articles and comments.
Members with questions may contact Detlefsen at email@example.com.