The Specialty Food Association testified at the FDA's public hearing, Wednesday, regarding the agency's final proposed rule under the Food Safety Modernization Act, introduced in September. The FSMA Food Traceability Proposed Rule identifies and creates increased traceability requirements for certain high-risk foods and products that contain those high-risk foods.
The proposed rule identifies five “critical tracking events” that would require records containing “key data elements,” which would vary depending on the event being performed. Food makers, co-packers, labelers, distributors, and retailers would have roles in this new proposed rule.
In a letter to the FDA, Ron Tanner, vice president for education, content, and advocacy for the SFA, said that although the Association supports improved food traceability, it's concerned about how members would be impacted by the proposed rule. Its main concerns include:
• The unclear definition of the general categories of foods for inclusion on the Food Traceability List
• How receiving manufacturers and distributors will be able to know whether a product qualifies for exemptions or partial exemptions without any labeling requirements by originating or preceding entities
• The lack of education and training regarding this rule
• How this rule will be enforced
In addition, the SFA encourages the FDA to:
• Focus on the collection of key data elements that are most relevant for ensuring effective traceback
• Implement an extended and phased timeline for compliance with this rule based upon business size and entity type
“As the trade association for the specialty food industry, SFA supports the overall goal of improved food traceability, the letter states. “We appreciate the opportunity to provide verbal comments on the proposed rule for Food Traceability and will submit comprehensive comments to the docket. We strongly support FDA extending the comment period by at least 60 days.” Read the full letter.
Related: FSMA Food Traceability Proposed Rule: What You Should Know; SFA Submits Comments Related to Strengthening Organic Enforcement.
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