FDA pilots on their way

After travelling on business and my first beach vacation of the year over the Easter weekend, I thought it is time to catch up with some of the regulatory progress that FSMA (the Food Safety Modernization Act) has made over the past few months. Even though I deal a lot with the red-meat industry, people may think why bother, since FDA is not regulating meat, but stay with me for a second and you will see why.

Traceability has probably been the most dominant topic in industry publications for the past couple of years including this blog. Traceability systems are the ways and means we are using today to perform recalls. The problem that FSMA tasked FDA is resolving the speediness of the recalls, which in the PBA case, the Jalapeno case and the spinach case took weeks until the ultimate source of an outbreak was found, contaminated product removed from the shelves and a lot of innocent businesses harmed. The first step to redefine how traceability systems need to work in the future, FDA and IFT worked together on defining pilot studies to see what is feasible to do. Consider these pilot studies ‘feasibility studies’. The cases that FDA has defined have been published on FDA’s blog and the include Tomatoes, Peanut Butter and Kung Pao Style Chicken. Read the full blog entry real careful!

Kung Pao Style Chicken! If you have followed the history of these pilots, you may have noticed that they were tasked to do just 2 pilots and came up initially with Peanut Butter and Tomatoes. Regulators in FDA and IFT must have thought something like “Let’s look for some serious trouble!” While the first two supply chains are practically entirely contained within the regulatory domain of FDA, Chicken is not!

What do we expect to find out from these studies? I guess the result is clear: Traceability technology that FDA is going to mandate for its foods must be sooner or later expanded to all USDA regulated foods. This means that either the entire effort of making our recall systems faster will stall, because of some pretty obvious large holes, or we will look at another large change in our traceability system requirements for the entire food industry this time around. Stay tuned, the results of the pilots are expected at the end of summer. Enjoy the summer!

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