A proposed rule to expand traceability requirements for high-risk foods is unnecessarily complex and should be rewritten, UEP said in comments filed with the Food and Drug Administration (FDA).

UEP said the regulation “is unnecessarily complex” and will generate information that is “superfluous and not easily used by the recipients.” Especially for small farms, the rule will create new burdens, UEP said.

Among UEP’s criticisms of the proposed rule:

• It would create confusion by using a different definition of “farm” than used in all other regulations that implement the Food Safety Modernization Act;
• The regulation’s reporting categories are unclear and many questions about the responsibilities of reporting companies are left unanswered; and
• Information required to be supplied by all shippers – apparently including small contract farms – would in some cases be business-sensitive and irrelevant to the receiving entity.

UEP recommended that FDA make major changes and re-propose the rule, so that the public has a chance to comment on the revisions.