In comments filed yesterday with the Food and Drug Administration, IDFA supported the agency's long-term strategic plan to improve effectiveness and efficiency under its Foods and Veterinary Medicine Program. Agreeing that the implementation of the Food Safety Modernization Act (FSMA) should be a top priority, IDFA urged FDA to help spur innovation by modernizing food standards and good manufacturing practices and completing rulemaking on yogurt and ultra-filtered (UF) milk. The plan outlines the agency's priorities for 2012 to 2016.

"IDFA was a strong supporter of FSMA during the legislative process and continues to support FDA during implementation. Development and application of science-based preventive controls are vital to the new law's success," the comments stated. "Issuance of a proposed rule on preventive controls should be a very high priority for the agency."  

One-Third of Standards Cover Dairy Products

Noting that more than a third of all FDA food standards cover dairy products, IDFA urged the agency to modernize the food standards process and allow changes for non-characterizing ingredients without requiring new rulemaking. This change would enhance the industry's ability to innovate quickly and save FDA considerable resources, without any negative impact on consumers.

IDFA also called for FDA to finalize rulemaking that would allow UF milk to be used in standardized cheese products and update the standards of identity for yogurt. Waiting years for these rules to become final has hindered opportunities for greater dairy product innovation and growth, the comments stated.

Timely testing and reporting of import and domestic samples are also important to the industry, especially for perishable products. As the agency increases its inspections of food facilities and begins to enforce the new preventive controls requirements, IDFA asked FDA to conduct sampling and report results in a timely and transparent manner.

IDFA also offered suggestions for improving or clarifying several food safety provisions.

  • Modernize the good manufacturing practices, or GMPs, which were last modified 25 years ago. IDFA believes increased regulatory attention to sanitation, employee training, and environmental and allergen controls would improve food safety.
  • Continue to rely on inspections for Grade A milk facilities by the states to ensure compliance with the Pasteurized Milk Ordinance (PMO).

'Allow Any Safe and Suitable Sweetener'

In the area of nutrition, the comments urged FDA to grant IDFA's petition, filed jointly in 2009 with the National Milk Producers Federation, to allow any safe and suitable sweetener to be used in sweetened milk products, including flavored milk.

"This petition is especially timely, as the First Lady's 'Let's Move' initiative properly focuses attention on steps that can and should be taken to combat childhood obesity," the comments said. "Because flavored milk is strongly preferred by many children, one way to reduce caloric intake is to allow alternative sweeteners that have zero or very few calories to be used in flavored milk."

Members with questions may contact Cary Frye, IDFA vice president of regulatory and scientific affairs, at cfrye@idfa.org.

Read the full comments here.