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IDFA Supports Relying on NCIMS, USDA for Plant Inspections

Jul 06, 2011

In comments filed today, IDFA urged the Food and Drug Administration to rely on the current oversight system for Grade "A" products provided by the National Conference of Interstate Milk Shipments (NCIMS) when mandating inspection frequency under the new Food Safety Modernization Act (FSMA). In addition, IDFA encouraged the agency to continue working with the U.S. Department of Agriculture for oversight of non-Grade "A" products.

This is the third set of comments filed by IDFA in response to FDA's requests for industry input on various sections of the new food safety act. This request focused on enforcement authorities for inspections and compliance, the frequency and targeting of facility inspections, and inspections in a preventive-controls environment.

In the comments, IDFA said relying on existing partnerships would allow FDA to leverage the capabilities of highly qualified state and federal officials, avoid duplicative inspections and use its limited resources to inspect facilities in other sectors that don't currently have inspection programs in place.

"IDFA believes that reliance on these state and federal inspections of dairy facilities represents a 'win-win' under the FSMA," the comments stated. "These results are good for public health, as well as the overall administrative efficiency of the FDA inspection program."

In addition, IDFA encouraged the agency to consider the existence of effective food safety plans, which virtually every dairy processing plant has in place, in determining which plants would be deemed high risk. IDFA said these plans should be reviewed during onsite inspections, not filed in advance, because it's critical for inspectors to see the plans in action.

"In our view, there are no high-risk foods, only high-risk facilities," the comments stated. "Even foods that support the survival and growth of pathogens (e.g., milk), can be (and almost always are) produced and distributed safely under effective preventive control systems. Indeed, the pasteurization of milk and other dairy products is one of the most longstanding and effective pathogen-control mechanisms in the entire food supply."

Read IDFA's comments here.

For background, read IDFA's earlier comments.

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



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