IDFA submitted comments last week to the Food and Drug Administration regarding the product tracking and traceability provisions of the Food Safety Modernization Act (FSMA). Recognizing the crucial role that traceability plays in food safety, IDFA highlighted current voluntary efforts undertaken by dairy and other food industries and encouraged FDA to restrict additional recordkeeping requirements to “high-risk” foods.

FDA requested comments in response to its report, released in March, about the results of two product traceability pilot projects conducted by the Institute of Food Technologists under contract with FDA. The projects were designed to explore and demonstrate methods for rapid and effective tracing of food, including types of data that are useful for tracing, ways to connect points in the supply chain and how quickly data can be shared with FDA. The pilots were mandated by FSMA, which also requires FDA to establish recordkeeping requirements for high-risk foods to help in tracing products.

One-Up, One-Back Regulations

IDFA identified prioritizing industry compliance with current “one-up, one-back” traceability regulations issued under the Bioterrorism Act of 2002 as a priority area for FDA to consider.

“We believe that delays and complications during recent recall investigations have been the result of poor compliance on the part of some food industry members. These issues do not reflect fundamental deficiencies in the current system,” the comments said. “FDA should work with industry to fully implement the existing rules before it considers more extensive recordkeeping requirements.”

In addition, IDFA encouraged FDA to create a standardized electronic platform for reporting traceability data and to support industry efforts already underway to improve traceability. The comments also mentioned two voluntary industry traceability initiatives: the draft “Traceability Implementation Guide” for the U.S. dairy, deli and bakery industries and the draft “Guidance for Dairy Product Enhanced Traceability” issued by the Innovation Center for U.S. Dairy.

Once comments have been reviewed, FDA plans to begin the rulemaking process on recordkeeping requirements for high-risk foods to help with traceability efforts. FDA will establish a definition of high-risk foods based on foodborne illness data, the likelihood that the foods have high potential for contamination and the severity of the illness attributed to those foods.

• Read the comments here.

For more information, contact Clay Detlefsen, IDFA vice president of regulatory affairs, at cdetlefsen@idfa.org.