Based on the work IFT has conducted in the area of product tracing, which is related to recordkeeping, IFT was pleased to submit commits concurring that the proposed collection of information is necessary for the proper performance of FDA's functions. This information does have practical utility, but information pertaining to product transformations also needs to be considered to ensure comprehensive internal traceability.
March 14, 2011
As the adoption of electronic technologies by the food industry increases over time, the burden associated with data collection should decrease. To enhance the quality, utility, and clarity of the information to be collected, FDA should encourage the adoption of standard ways to express this information (for example, encouraging a uniform way of expressing date and time) without prescribing the exact standard, which should be selected by industry. However, IFT believes that the food industry must first determine the Critical Tracking Events (CTEs) and the Key Data Elements (KDEs) necessary for product tracing. Through this exploration, IFT expects that certain standards will be recognized. To minimize the burden of the collection of information on respondents and FDA in a time of investigation of a food outbreak, FDA should encourage the food industry to capture these records in an electronic format in the interest of accuracy and efficiency of analysis, including through the use of automated collection techniques, when appropriate, and other forms of information technology. FDA should also have systems and mechanisms in place to accept electronic records.
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