IFT provides comments on FDA’s recordkeeping and records access requirements for food facilities

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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