Feed association cautions FDA on limitations of product-tracing systems

The National Grain and Feed Association has cautioned the U.S. Food and Drug Administration about the limitations of product-tracing systems for industries that handle large volumes of commingled commodities.
At a joint public meeting held by the FDA and the U.S. Department of Agriculture’s Food Safety and Inspection Service, the NGFA submitted a statement warning that overemphasis on such systems could divert finite human and financial resources away from efforts focused on preventing food and feed safety hazards. The NGFA said that prevention of hazards posing a risk to human or animal health should be the “primary focus” of both government and industry.
The NGFA said that the grain, feed and grain processing industry is covered by the Bioterrorism Act of 2002 requirement that facilities maintain records sufficient to identify the immediate previous source and next subsequent recipient of products they receive and subsequently ship, as well as the identity of the transporter used to distribute such products.
But the NGFA said traceability systems, “while certainly a tool as part of a comprehensive food/feed safety program,” are “reactive, rather than preventive” and “should not be considered in a vacuum or as a ‘be-all and end-all.’”
The NGFA said it believed any new product-tracing requirements imposed by government should be based upon the safety risk posed by the underlying commodity or food/feed product, as determined by a comprehensive risk assessment that considers past foodborne illness incidents and their severity.
The association urged the FDA to consider the impact of the government’s new Reportable Food Registry before considering additional product-tracing requirements. The Reportable Food Registry, activated in September, aims to increase the speed and accuracy of product tracing and specifically targets products that facilities determine may pose a serious risk to human or animal health.