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IDFA Submits Comments to FDA on Five-Year Strategic Priorities

Nov 05, 2010

In comments filed this week with the Food and Drug Administration, IDFA agreed in general with the agency's strategic priorities and recommended adding a companion plan for implementation, especially for FDA food initiatives. Specifically, IDFA urged the agency to modernize food standards and good manufacturing practices, complete pending rulemaking on yogurt and ultra-filtered milk, and resolve other issues that IDFA believes would strengthen the safety of the supply chain from a global, national and local perspective.

In September, FDA unveiled the draft five-year strategic plan that aims to:

  • advance regulatory science and innovation,
  • strengthen the safety and integrity of the global supply chain,
  • strengthen compliance and enforcement activities to support public health and
  • focus on food safety prevention and improved nutrition.

"Our principal comment is that the strategic priorities are a good first step, but that FDA should take the next step and issue an annual implementation plan for each center," the comments state. "For the food program, this is particularly important given the breadth of activities and, therefore, the need to focus on the highest priority initiatives."

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 ultra-filtered (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. IDFA asked FDA to conduct the sampling and report results promptly to minimize market disruption.

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, among others, would significantly improve food safety.
  • Finalize the definition of "transfer" pertaining to the Reportable Food Registry. IDFA states that "transfer to another person" should not apply when food products are held under company control at a third-party warehouse, because this arrangement poses no threat to public health.
  • Continue to rely on inspections for Grade A milk facilities by the states to ensure compliance with the Pasteurized Milk Ordinance (PMO).
  • Continue to ensure that raw milk is not sold interstate and educate consumers about the dangers of consuming raw milk.

In the area of nutrition, the comments urged FDA to grant IDFA's petition, filed jointly last year with the National Milk Producers Federation, to allow any safe and suitable sweetener to be used in sweetened milk products, including flavored milk. IDFA also reiterated its belief that front-of-package labeling should be voluntary and include nutrients to encourage.

Read the full comments here.

Members with questions may contact Cary Frye, IDFA vice president of regulatory affairs, at


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