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Dairy Facts 2016

IDFA, NMPF Submit Comments to FDA on Preventive Controls

May 25, 2011

In joint comments submitted last Friday, IDFA and the National Milk Producers Federation urged the Food and Drug Administration to consider existing preventive control programs when it drafts regulations for implementing the Food Safety Modernization Act. They also asked the agency not to mandate finished product testing, because it would impose considerable costs for companies without adding any public health benefit.

Echoing the oft-repeated government statement that "you cannot test your way to food safety," IDFA and NMPF agreed that pasteurization is the key to assuring the safety of milk and other dairy products. They encouraged FDA to align any new regulations with the Pasteurized Milk Ordinance (PMO) and focus on the validation of pasteurization systems, not finished products, to ensure public health and safety.

"We believe that if Congress intended to mandate finished product testing, it would have done so in a clear and unambiguous manner," the comments stated. "It is important to note that the PMO does not mandate pathogen testing of finished product."

IDFA and NMPF also asked FDA to limit warehouse requirements, as allowed by the Food Safety Modernization Act, because many of the preventive control provisions would not apply. They agreed that warehouses should be expected to follow general controls for sanitation, pest control and inventory management.

Responding to a suggestion for companies to submit their food safety plans to FDA, IDFA and NMPF voiced opposition. They noted that the plans are best understood in the context of the plant, where inspectors can see the plan in operation, gain insight from discussions with plant employees and examine related records.

FDA is accepting comments on different sections of the Food Safety Modernization Act to gather input and encourage industry participation prior to its rulemaking process. Earlier this month, IDFA submitted comments on imported foods under the act and will submit additional comments on compliance and enforcement later this year.

Read the comments on preventive controls here.

For more information, contact Clay Detlefsen, IDFA vice president of regulatory affairs, at


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