July 23, 2020
The FDA announced the release of the "New Era of Smarter Food Safety" on July 14. The blueprint represents a new approach to food safety, leveraging technology and other tools to create a safer and more digital, traceable food system.
This initiative builds on the work the FDA has already done through implementation of the Food Safety Modernization Act (FSMA). While FDA had originally planned to unveil the blueprint in the spring of 2020, plans were paused so FDA could focus on COVID-19 pandemic response efforts.
Food safety continues to be a central mission for UEP farmer-members. UEP developed a close professional relationship with FDA when the agency developed and implemented the Egg Safety Rule (21 CFR 118). UEP members have implemented food safety protective and preventive measures that go beyond what the rule requires, including vaccination protocols and participation in rigorous, third-party verification programs such as Safe Quality Food.
The "New Era of Smarter Food Safety" blueprint is centered around four core elements: (1) tech-enabled traceability, (2) smarter tools and approaches for prevention and outbreak response, (3) new business models and retail modernization and (4) food safety culture.
UEP Senior VP of Food Safety Regulatory Affairs Oscar Garrison, who was a food safety regulator for 20 years and a past-president of the Association of Food and Drug Officials, provided the following insights regarding the blueprint: “The regulatory approach to food safety is due for a change. By using data to drive regulatory decision making, incorporating the tracing of foods, and building a food safety culture within food production facilities, foodborne illness can be reduced in this country.”
In meetings with senior officials at FDA and original comments on the blueprint, UEP highlighted several priorities, detailed below, which are planned for the egg industry to support the blueprint and to engage with the agency moving forward.
The FSAC was recently reestablished to include recognized experts in toxicology, epidemiology, genomics, regulation, sampling methodology, academia and research and a variety of other fields. Members serve on an unpaid basis to assure objectivity, and the council has the following mission: To provide input and insight to UEP on current and future issues affecting the industry such as food safety initiatives and programs; microbiology and emerging pathogens; research needs and results; epidemiology and whole genome sequencing; educational needs and availability; and the changing regulatory environment.
UEP is also interested in opportunities for direct partnership with the agency. In particular, UEP has identified a need to educate small-scale egg farms in food safety best practices including, but not limited to, compliance with the Egg Safety Rule. Many of these farms are not members of UEP and therefore are not regularly exposed to the food safety information and educational programs that benefit UEP members. The growing popularity of egg sales through farmers’ markets and similar venues makes it increasingly important to ensure that good food safety practices are implemented at all scales of production, including the smallest.
UEP recognizes that whole genome sequencing offers substantial benefits in the identification and attribution of foodborne illness outbreaks. At the same time, UEP has identified a need for additional transparency, public dialogue and informed expert consensus on standards for finding a “match” between, or among, different samples.
UEP recommends that the agency consider the implications of enhanced detection and attribution capabilities which, in practical terms, may mean the identification of numerous “outbreaks” consisting of a handful of cases – cases that in the past would not have been classified as part of an outbreak.
UEP also sees a need for FDA to enhance its communication with food companies during traceback investigations. For example, during previous investigations, substantial delays in communicating the results of FDA testing led to uncertainty for the company about appropriate corrective actions. The need for real-time communications will enhance the ability of both producers and FDA to prevent foodborne illness.
UEP supports the agency’s blueprint, and commends FDA, and Deputy Commissioner Yiannas in particular, for highlighting the need to apply the latest technologies to increase safety and transparency in the food supply. UEP plans to work cooperatively with FDA to further reduce the burden of foodborne illness and to promote food safety improvements that ensure that the U.S. continues to have the world’s safest food supply.
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