IFT Comments on FDA’s Food Protection Plan

On July 31, 2008, the Institute of Food Technologists sent comments and recommendations to the Food and Drug Administration on its recently announced Food Protection Plan (Docket No. FDA-2008-N-0188). Following is a synopsis of the comments; a complete full-text version is available online at www.ift.org. IFT agrees in general with the plan’s core elements of Prevention, Intervention, and Response. To strengthen the plan, IFT recommends that the FDA:

• Seek to achieve the overarching goal of safety of all foods for all people. To reach this goal, the science component, including staffing, of FDA must be strengthened. Current lab facilities and IT systems need to be modernized and the scientific expertise of the agency can be enhanced. The scientific component of the FDA must be maintained at a level that permits the agency to effectively exercise its responsibilities.

• Expect corporate responsibility for food safety management. IFT recommends that food manufacturers, regardless of size, respond to the plan with establishment-and product-specific food safety management systems that incorporate management’s understanding of its corporate responsibility for ensuring food safety.

• Verify that each food manufacturer uses Hazard Analysis and Critical Control Point (HACCP) criteria in conducting and documenting a hazard analysis of its operations and establishing critical control points (CCP) to control significant identified hazards. When CCPs cannot be established (e.g., in commodity handling operations), appropriate preventive controls should be applied within the available HACCP prerequisite programs (e.g., good manufacturing practices).

• Conduct outreach and education to promote and enable across-the-board implementation of food safety management systems. IFT urges increased federal efforts and support of activities to educate food industry and other personnel having food safety responsibility throughout the food system on the need for food safety management systems and train them in effective implementation. This should be a joint effort involving regulatory and food industry leaders.

• Enhance collaborative efforts with other agencies, including those at the state and local level, academia, and industry, using all pertinent data to inform policy decisions and focus limited resources on known hazards. IFT advises that FDA consider closer collaborations with academia, an important scientific component in determining food policy. Greater collaborative efforts with universities could be helpful in filling in scientific data gaps, and increased funding for universities would enhance the needed outcomes of basic and applied research.

• Further enhance content in existing inventories of food safety programs by country, including food exports and any particular concerns. Data and information available within FDA or other agencies would be helpful to the food industry in implementing or enhancing food safety management systems. Specific information about countries, regions, and food safety programs of concern could be very useful to the food industry’s efforts to enhance food safety and food defense.

• Promote usage and consistent application of scientifically based third party certification for domestic and international manufacturers of food ingredients and products based on internationally recognized criteria. IFT applauds the recent release of Draft Guidance of Voluntary Third-Party Certification Programs for Foods and Feeds, and supports FDA’s interest in the use of third party audits that are scientifically based and consistently applied and enforced as an additional tool to further strengthen food safety management systems.

• Support further development and capacity building of international food safety programs. IFT believes that establishment of an intergovernmental food safety agency, such as a “World Organization for Food Protection,” would be valuable for leading the coordination and education that is needed for implementation and verification of food safety management systems worldwide.

• Maintain momentum in food defense along with food safety, as integral and integrated components of food protection. Include specific food defense measures and modeling, research, and information needs in the Food Protection Plan.

IFT hopes that FDA finds these comments useful and extends an invitation to FDA to discuss any of these points. Also, IFT feels well-positioned as a scientific, professional society to assist the agency in developing educational and training materials to advance food protection practices.