Some of the factors that FDA will weigh as it determines what are high-risk foods include outbreak frequency, illness occurrence, severity of illness, the likelihood of microbial or chemical contamination, potential for the food to support pathogen growth, food consumption patterns and the probability of contamination and steps taken during manufacturing to reduce contamination.
The FDA also will look at health and economic factors, cost of illness and disabilities expected, according to the FDA notice.
One of Acheson’s colleagues at The Acheson Group, Jennifer McEntire, vice president and chief science officer, told me this week that the FDA is under no hard deadline to produce this rule, unlike the 2015 deadline for the produce safety rule and other major FSMA regulations.
Even so, she said the FDA’s designation of “high-risk” foods is drawing a lot of food industry attention.
She thinks that the way FDA has proposed their matrix of scoring risk, nearly all commodities could be labeled “high risk.”
“How will they draw the line between high risk and what is not?” she said.
The question of risk methodology that the FDA is currently seeking advice on is just a prelude to the main show.
Once the FDA actually identifies the specific food items that are high risk, watch out. Fortunes will be spent, I would think, in either keeping commodities off the “high risk” list or trying to extract them if they are shamed and named.
The FDA can only solve this by making every food high risk — or dumping the idea entirely. Since the latter isn’t likely, prepare for the former. High risk, yes, but consider the rewards!
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