By: Stephanie Harris, Chief Regulatory Officer, FMI

FDA buildingLast year, the U.S. Food and Drug Administration (FDA) announced the agency’s plans for a new approach to food safety, a so-called “New Era of Food Safety,” that will emphasize the use of technology and other available tools to further improve the country’s food safety system. The agency’s new plan is designed to build on the many improvements seen through the recently implemented Food Safety Modernization Act (FSMA) while using existing means to work on key food safety issues, such as responding to foodborne outbreaks and improving methods to prevent and mitigate food safety risks.

As FDA explained it, “It’s also about simpler, more effective, and modern approaches and processes. Smarter Food Safety is people-led, FSMA-based, and technology-enabled.”

FDA held a public meeting in October to discuss the new food safety program and requested written comments in addition to the feedback received at the public meeting. I provided oral remarks at the public meeting, and we submitted written comments on behalf of the industry, which were compiled with the help of many of the food safety and policy professionals at our member companies.

Our comments focus on several key principles, including focusing on outcomes; leveraging existing tools; increasing communications with stakeholders; accounting for the food industry’s variable resources and abilities; and how uniformity will promote success.

Tech-enabled traceability and foodborne outbreak response

New and evolving digital technologies will play a pivotal role in traceability moving forward. We encourage FDA to allow for flexibility in the adoption of technology to allow for innovation now and in the future. The agency should provide flexibility regarding the technology used for traceability and should recognize that there are multiple ways for companies to embrace technology to improve food safety and traceability. 

Smarter tools and approaches for prevention

Regardless of what technologies are used, we encourage FDA to identify essential data elements necessary for food safety and public health purposes that should be collected and shared throughout the supply chain. Simplifying key data elements will speed up investigations and streamline the critical information that must be communicated to improve response time and accuracy. The collaboration between stakeholders and the agency is critical to both responding and preventing food safety problems at the outset. Critical stakeholders and the agency should be committed to sharing timely information on outbreaks and contamination to better understand learnings and ways we can work together to prevent food safety events in the future. Transparency throughout investigations is also essential so both the agency and industry can improve based off past learnings. 

New and emerging business models and retail food safety

Business models are rapidly changing, and any regulatory framework should be broad in nature or have the ability to be flexible to adapt with business practices. Where there is a need to address potential risks, FDA should utilize existing organizations and forums such as the Conference for Food Protection (CFP) to bring together all stakeholders to collaboratively develop food safety solutions to protect public health. As FDA evaluates the new era of smarter food safety, we welcome opportunities to advance retail food safety to place more focus on public health protection.  FMI was pleased to see that FDA is considering the ways in which the agency and its state partners can enhance their oversight of existing retail business models.  We believe one of the greatest areas for improvement would be to achieve greater consistency in food retailer inspections and more consistent adoption of the FDA Food Code.  

Food safety culture

We support FDA’s approach to promoting food safety not just within industry, but among regulators and consumers as well. Because a food safety culture can look different from business to business, we encourage FDA to explore the ways in which the agency can act as a resource in this area to help companies enhance their food safety culture, without setting prescribed metrics or standards. Overall, food safety culture should be fostered, not regulated. We urge FDA to encourage stakeholders to provide accurate and science-based consumer food safety information that is not misleading. Providing consumers with accurate and meaningful information is of top importance in maintaining public confidence in the food supply.

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