Just a step ahead of the U.S. Food and Drug Administration’s release of two rules for improving imported food safety, the Association of Food and Drug Officials (AFDO) has published its own guidance document entitled “Issues and Concerns with Imported Foods.” AFDO is an international nonprofit professional association based in York, PA. It says that it put the guidance for imported foods online as a quick resource for field inspectors. The AFDO guide gives a brief explanation of the imported food process and a directory of the agencies involved. It also provides definitions and photo examples of violative products, unapproved ingredients and additives. Two years ago, imported foods entering the U.S. for the first time exceeded 10 million import lines, and AFDO says that number is expected to continue to grow at a rapid rate. The group also says that while fewer than 1 percent are physically examined, all are electronically reviewed using a “risk-based targeted approach.” “Once these FDA-regulated products enter the United States and are marketed domestically, they become the primary responsibility of state and local agencies to ensure the product’s safety,” notes the AFDO guidance document. “Surveillance of imported foods by federal, state, and local food-protection agencies has resulted in many regulatory actions including food sampling and testing, food seizure and embargo, destruction of violative products, Class I, II, and III food recalls, and FDA import Alerts,” the guidance adds. FDA’s electronic review is called Predictive Risk-Based Evaluation for Dynamic Import Compliance Targeting (PREDICT). The AFDO report says PREDICT considers factors such as whether the food is intrinsically risky due to recent weather in the originating country. AFDO calls U.S. Customs and Border Protection (CBP) “the first line of defense” for the safety of imported foods. That’s because CBP collects entry documents from importers and agents before review by FDA. In addition to FDA and USDA, the guidance document calls out the U.S. Environmental Protection Agency (EPA) and the U.S. Fish and Wildlife Service as the key agencies for border enforcement actions. FDA on July 26 came out with two rules implementing the imported foods language in the two-year old Food Safety Modernization Act. Now in the comment period, the proposed rules require importers to verify that their suppliers are employing prevention-based practices and sets up a system for certifying third-party auditors. The goal of the two rules is to shift from a regulatory system based on catching problems at the border to preventing problems before they get here. The AFDO guidance document seems to suggest that state and local officials should not stop looking for problems with imported foods. The online document lists and provides examples of such things as food color additives banned in the U.S., microbiological contamination, undeclared allergens, banned antibiotics and lead-contaminated food packaging.