Good afternoon. My name is Stephanie Harris, Chief Regulatory Officer and General Counsel at FMI- The Food Industry Association. FMI is the trade association that advocates on behalf of a wide range of members within the food industry value chain, from food wholesalers and suppliers to grocery retailers. FMI strongly supports food safety compliance and sharing best practices in order to provide consumers with safe products and to protect public health. FMI members openly share food safety information to assist the entire industry with their food safety management programs.
Full CommentsFMI Comments delivered on October 20, 2021 by Stephanie Harris, Chief Regulatory Officer & General Counsel New Era of Smarter Food Safety Summit on E-Commerce: Ensuring the Safety of Foods Ordered Online and Delivered Directly to Consumers FMI Comments Good afternoon. My name is Stephanie Harris, Chief Regulatory Officer and General Counsel at FMI- The Food Industry Association. FMI is the trade association that advocates on behalf of a wide range of members within the food industry value chain, from food wholesalers and suppliers to grocery retailers. FMI strongly supports food safety compliance and sharing best practices in order to provide consumers with safe products and to protect public health. FMI members openly share food safety information to assist the entire industry with their food safety management programs. We plan to submit more detailed written comments; however, there are several issues we think are important to raise at this summit. 1. Food delivery is not new. There are many different models over many decades – from pizza delivery, milk delivery and even frozen products delivered directly to consumers at home. Consumer expectations and consumer satisfaction are at the root of this business model. The market drives innovation because keeping customers is becoming more and more competitive. 2. Because business models will continue to change rapidly due to technological innovations as well as consumer expectations, the FDA and other public health regulatory agencies should focus on outcomes (that consumers receive safe food) and FMI Comments delivered on October 20, 2021 by Stephanie Harris, Chief Regulatory Officer & not the process (how they receive it). Since 2020 we have seen double digit growth in General Counsel online shopping with almost 90% of FMI member companies reporting the use of online New Era of Smarter Food Safety Summit on E-Commerce: Ensuring the Safety of Foods Ordered Online and Delivered Directly to Consumers shopping and alternative delivery methods for consumers. Additionally, two thirds of FMI Comments consumers report that they have shopped for food online. Businesses will continue to Good afternoon. My name is Stephanie Harris, Chief Regulatory Officer and General respond to consumer demand and businesses will continue to innovate. Counsel at FMI- The Food Industry Association. FMI is the trade association that advocates on 3. There already is a strong legal framework ensuring the safety of foods delivered behalf of a wide range of members within the food industry value chain, from food wholesalers through new business models. This starts with the general prohibition on introducing or and suppliers to grocery retailers. receiving adulterated or misbranded food in interstate commerce, or adulterating or FMI strongly supports food safety compliance and sharing best practices in order to misbranding food. More specific details are found in the Food Code, the Preventive provide consumers with safe products and to protect public health. FMI members openly share Controls for Human and Animal Food regulations, and the Sanitary Transportation of food safety information to assist the entire industry with their food safety management Food requirements to name a few. We encourage the FDA to carefully evaluate existing programs. requirements and to exercise enforcement authority when appropriate before We plan to submit more detailed written comments; however, there are several issues we developing new, additional, or different regulations for new business models. think are important to raise at this summit. 3. A strong starting point for education and evaluation should be a recently released 1. Food delivery is not new. There are many different models over many decades – from document from the Conference for Food Protection titled “Guidance Document for pizza delivery, milk delivery and even frozen products delivered directly to consumers at Direct-to-Consumer and Third-Party Delivery Service Food Delivery” (CFP 2020). This home. Consumer expectations and consumer satisfaction are at the root of this business was developed by a multidisciplinary committee within CFP and includes broad model. The market drives innovation because keeping customers is becoming more consensus of food safety and public health professionals. This document addresses and more competitive. 2. 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AddThitionale industly, twryo t wihill crds ontiof nue FMI Comments cto onsuminnovate ers reand port whithatle e tnhsuriey hng ave shfood oppedsafety fo is at r foothe d onlitop ne. of t Businhe priesses ority lwistil wl chen ontinue servito ng Good afternoon. My name is Stephanie Harris, Chief Regulatory Officer and General crespondustomers to cdayonsum in aner d dadeymand out. and businesses will continue to innovate. Counsel at FMI- The Food Industry Association. FMI is the trade association that advocates on Finally, w3. Te enchereourage alreadythe is a st FDAr too cng ontilegalnue frameto engworkage en wsuitrih ng thethe food i safetyndu ofstr foy andods food sdeliveredafet y behalf of a wide range of members within the food industry value chain, from food wholesalers professionthrough als to neobtaiw bn usiinness formmatiodelon and s. Thencis starts ourage wittheh th she aringgeneral of nov prohibel ideition as and on inbesttrod pucrainctig cor es and suppliers to grocery retailers. that will recheleip viproteng adulct puteratedblic h or ealtmih. sbrande d food in interstate commerce, or adulterating or FMI strongly supports food safety compliance and sharing best practices in order to misbranding food. More specific details are found in the Food Code, the Preventive provide consumers with safe products and to protect public health. FMI members openly share Controls for Human and Animal Food regulations, and the Sanitary Transportation of food safety information to assist the entire industry with their food safety management Food requirements to name a few. We encourage the FDA to carefully evaluate existing programs. requirements and to exercise enforcement authority when appropriate before We plan to submit more detailed written comments; however, there are several issues we developing new, additional, or different regulations for new business models. think are important to raise at this summit. 3. A strong starting point for education and evaluation should be a recently released 1. Food delivery is not new. There are many different models over many decades – from document from the Conference for Food Protection titled “Guidance Document for pizza delivery, milk delivery and even frozen products delivered directly to consumers at Direct-to-Consumer and Third-Party Delivery Service Food Delivery” (CFP 2020). This home. Consumer expectations and consumer satisfaction are at the root of this business was developed by a multidisciplinary committee within CFP and includes broad model. The market drives innovation because keeping customers is becoming more consensus of food safety and public health professionals. This document addresses and more competitive.
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