IFT Provides Comments on FDA’s FY 2011-2015 Strategic Priorities

October 29, 2010

Re: Docket Number FDA-2010-N-0506

To Whom It May Concern:

The Institute of Food Technologists (IFT) exists to advance the science of food.  Our long-range vision is to ensure a safe and abundant food supply contributing to healthier people everywhere.  Founded in 1939, IFT is a nonprofit scientific society with over 18,000 individual members working in food science, food technology, and related professions in industry, academia, and government.  IFT champions the use of sound science across the food value chain through knowledge sharing, education, and advocacy, encouraging the exchange of information, providing educational opportunities, and furthering the advancement of the profession.  IFT commends the FDA on development of the draft Fiscal Year 2011-2015 Strategic Priorities Document, and appreciates the opportunity to comment on such an important and critical initiative. 

IFT is supportive of the strategic goals, long-term objectives and desired public health outcomes for food safety, as well as dietary practices and nutrition, outlined in the draft Strategic Priorities Document.  IFT hopes that FDA will continue to build upon initiatives already underway, such as 1997's Food Safety Initiative and 2007's Food Protection Plan, as the Agency identifies new strategic priorities for each Fiscal Year, such as the forthcoming "Roadmap to Food Safety."

IFT was also pleased when the Office of Foods was created within the Commissioner's Office of FDA.  This deservedly elevated food safety to a new, increased level of recognition within the Agency; however, as the Office of Foods has grown and evolved, there has been a sense of duplication of efforts and at times, confusion in responsibilities.  IFT supports the "One Mission, One Program Initiative" and hopes that coordination of efforts across all FDA offices will be achieved.  IFT also recommends that the ten core groups that are part of this important initiative seek input from experts outside of the Agency to determine how best to unify and better coordinate FDA's Foods Program.

IFT is supportive of a prevention-oriented system that is based on scientific and risk-based principles and encourages FDA to include scientific expertise outside of the FDA when determining what constitutes "risk".  For example, many recent outbreaks have been due to Good Manufacturing Practices (GMPs) violations.  Careful consideration should be given to designating foods as "high risk" when contamination results from negligence.  Similarly, it is difficult to predict the next high profile outbreak and product recall that will result from non-conformance with the expected food safety practices.  IFT would not want a focus on "high risk foods" to inadvertently cause producers of "non-high risk" foods to become complacent in their food safety assurance practices and strategies.

As FDA establishes a sustained, multi‐faceted coordinated effort to reduce the level of sodium in processed foods, a strategy outlined in Section 3.1.2, IFT suggests a graduated reduction of sodium in processed foods, with partnership between the food industry and public health officials.  Moreover, adequate time must be given to the food industry to overcome food safety and processing challenges associated with sodium reduction.  IFT encourages FDA to work closely with food scientists and technologists in their coordinated effort to reduce sodium in processed foods. 

IFT strongly encourages the FDA to quickly identify the tactical approaches necessary to implement the strategic priorities outlined in this draft document.  There should be a real sense of urgency in implementing the strategic priorities that will benefit all Americans. 


Robert Gravani, Ph.D.
IFT President


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