Sponsored by the Association of Food & Drug Officials (AFDO), FSS sessions (“Integrating the Nation’s Food Safety System Forum”) focused on FSMA’s mandate to FDA—an Integrated Food Safety System (IFSS)—and featured FDA speakers and representatives from state and local governments. Other AFDO-sponsored sessions revealed industry and consumer concerns about the new FSMA regulations and their implementation.
IFSS leverages the participation, expertise and resources of partner agencies with food safety responsibilities to ensure a safe food system in the US. It draws from the Partnership for Food Protection (PFP), an FDA-supported compendium of states whose workgroups developed and implemented procedures, best practices and other work products to advance integration. PFP was charged with helping the development and implementation of IFSS.
“We’ve gone from an idea that regulators have been embracing and working on together for some time to a model that is now is embraced as the law of the land, and is part of the framework for a new, modern food safety system,” said Michael Taylor, FDA deputy commissioner for foods and veterinary medicine, at the opening of the FSMA/IFSS sessions. “This system is an affirmation of the work that has been going on and certainly will be a huge catalyst as we move along.”
IFSS, according to Speaker Jeff Farrar, FDA director of intergovernmental relations and partnerships, is already achieving its vision by:
- Establishing and implementing national standards to ensure consistency across all jurisdictions
- Developing training and certification programs to establish a highly skilled workforce across all jurisdictions and levels of government
- Ensuring food laboratory accreditation and providing food lab best practices to ensure consistent, meaningful data
- Implementing IFSS foundational elements (e.g., joint work planning, joint inspections where appropriate, sharing of inspection results, joint enforcement of compliance teams, coordinated and practiced responses to significant events, etc.).
According to Farrar, IFSS brings an increased compliance with FSMA laws and regulations; increases the ability to assess potential risks at domestic food facilities; provides more consistent and complete coverage of facilities across the food chain; improves food surveillance through integration of food facility inspection and information, environmental sampling and coordinated food sampling assignments; and improves response capacity and efficiency.
But there’s still work to be done as FSMA becomes law. Looking at the industry perspective, Jim Gorney, Produce Marketing Association vice president of food safety and technology, said there is an advantage with IFSS, and that is improving foodborne illness outbreak response times. “I can’t emphasize enough that the issues of accuracy and speed are essential. Everyone wants to know the potentially responsible party and the most likely food vehicle as quickly and accurately as possible.”
Gorney, who has been involved in some major outbreak investigations, said the states are the first responders, and they are crucial to an investigation. However, any investigation needs to be multi-jurisdictional with multiple agencies involved. More importantly, to make it all work, a coordinated effort with the timely sharing of information is necessary. After the response, there needs to be an educational outreach to the industry with lessons learned about the outbreak that just occurred.
The big issue, according to Gorney, is market access audits vs. compliance inspections with respect to FSMA implementation. He raised the following issues: How will states and FDA span the roles of educator, market access auditor and regulator? How can industry market access audit results be used to inform FDA/state work plans? USDA AMS and FDA are already working on harmonizing audit criteria and the FSMA Produce Rule requirements. But how does one harmonize auditor/inspector competency and proficiency?
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