The Food and Drug Administration is asking for feedback on a food traceability report released on Monday. The 300-page report, which looks at two pilot projects that were mandated by the Food Safety Modernization Act, along with the comments the agency receives, will inform a future rule on recordkeeping requirements that could vastly improve traceability in the food chain. The report, which involved numerous stakeholders, was crafted by the Institute of Food Technologists (IFT) over the past couple years. The organization conducted two pilot projects — one on tomatoes and one on chicken, peanut butter and spices used in processed food — designed to look at how food can be rapidly tracked and traced, what types of data are needed and how the data can be made available to FDA. On top of being chock-full of information on food tracing, the IFT report also makes several recommendations to FDA. IFT suggests, among other things, that the agency establish a uniform set of recordkeeping requirements for all all FDA-regulated foods, with no exemptions based on risk, and that each member of the food supply be required to develop a product tracing plan. The document also calls on FDA to be more clear in communicating what it needs from industry to conduct food tracing investigations and says FDA should considering adopting a technology platform that would allow “efficient aggregation and analysis” of data submitted to FDA on request. “We’re looking for input on where we should go with this information,” said Sherri McGarry, Senior Adviser to the CORE Network in the Office of Foods at FDA. McGarry noted that under FSMA, FDA is limited to requiring recordkeeping for high-risk foods, not all FDA-regulated foods. She said FDA would consider eventually issuing a guidance aimed at improving traceability for other low-risk foods not covered by the future rule. McGarry said that the agency has high hopes for improving traceability in the coming years. With improved technology and recordkeeping and data requirements, the FDA could one day visualize food supply chains and actually see how they interconnect and overlap during a foodborne illness outbreak, enabling investigators to hone in on the problem quickly. “[The report] is really encouraging,” said McGarry. “It gives us more specifics on what can be improved, both in the industry and at FDA.” FDA requested the information to help the agency form its own recommendations on improving traceability, which it will ultimately offer in a Report to Congress, as mandated by FSMA. “The produce industry has been looking forward to these traceability recommendations to make sure that we can move confidently with the traceability best practices that we have collectively developed in the [Produce Traceability Initiative],” said Mike Agostini, Senior Director of Produce at Wal-Mart Stores and co-chair of the PTI Leadership Council, in a statement on Monday. “Our industry community is excited to have the opportunity to delve into the details of the report and provide feedback to FDA.” FDA invited those interested in submitting comments to do so over the next 30 days. To submit comments electronically, go to and enter docket number FDA-2012-N-1153.

  • johnmunsell

    FDA is more committed to tracebacks to the source than FSIS has been in the past.  Consider these facts about FSIS’ recalcitrance to perform tracebacks to the SOURCE, thus circumventing traceability initiatives:

    1.  In March, 1998, FSIS issued a “Guidance for Beef Grinders to Better Protect Public Health”.  The Guidance made 21 references to Traceback, Tracking, Traceability, etc.  In spite of this Guidance, FSIS forbade their inspectors to document the SOURCE of ground beef being tested, at the time of sample collection.  FSIS investigations started, and finished, at downstream grinding plants.  No traceability here.

    2.  Twelve years later, on October 8, 2010, via FSIS Notice 58-10, FSIS for the first time authorized their inspectors to gather SUPPLIER information at the time an inspector collects a meat sample for microbial analysis.  It’s hard to imagine that FSIS, prior to 2010, did NOT allow thorough documentation of source evidence, which is required for traceability purposes.  Ironically, five years earlier on FSIS Notice 29-05, FSIS mandated documentation of supplier information when sampled meat originated from a foreign establishment.  FSIS doesn’t fear foreign slaughter establishments.

    3.  On August 3, 2011, USDA Secretary Tom Vilsack gave a public speech in which he gave FSIS 90 days to announce the first step in transforming its Traceback Policy.  Again, it’s hard to imagine that FSIS’ traceback policy had been nonexistent; in fact, their unwritten policy PREVENTED documentation which would have allowed tracebacks to occur.

    4.  But the unwillingness to document all source evidence, in a timely fashion, has not been unique to FSIS.  During a FSIS public hearing on March 10, 2010, the American Meat Institute’s VP for Food Safety and Inspection Services, Scott Goltry, provided comments which included the following shocker:  “AMI is unaware if a change to the trace back follow up sample procedure would have a significant improvement to public health”.

    Bottom line:  neither FSIS nor the largest packers (represented by AMI) want to determine the SOURCE of contaminated meat.  Both entities prefer to forward all liability downstream, thus insulating the large source slaughter providers from fecal accountability.  If such refusal to document all evidence constitutes “science-based” meat inspection, FDA should implement a different style of science.  Otherwise, the FSMA will be but an exercise in paperwork futility, empowered by pseudo science and an abAndance of caution.

    John Munsell