Are there traceability requirements in the produce rule?
No. Traceability proposals will come later in a proposal on recordkeeping.
The recordkeeping components in the proposed produce rule are not traceability proposals. Before traceability proposals can be made, FDA must report on a traceability pilot project. It was completed last June, and its report to Congress on the findings is still pending.
Until FDA’s final traceability requirements are released, existing U.S. traceability regulations requiring many companies to trace products one step forward and one step back per the Bioterrorism Act of 2002 remain in force.
No changes need to be made now. Instead, educate yourself and assess how this proposal will affect your business, then let FDA know your thoughts through the comments process.
To help you understand the rule, PMA has made a wide range of tools and information openly available through its FSMA Resource Center.
Of note, summaries of the proposed produce rule and the proposed preventive controls rule can be found there to help you understand the potential impact on your operation.
However, it is important that all companies continue to develop and update robust food safety programs, even as this regulatory process plays out.
Our industry and your company cannot afford to put food safety on hold pending final regulations and enforcement timelines, some of which will be up to six years from the date of the final rule.
Consumer confidence in our industry and its products are essential to our success, and demonstrable food safety is a key component to building that confidence.
Several years from now FDA will enforce final rules developed from these proposals and comments.
Dialogue among stakeholders and with your trade associations will help provide FDA with comments by the May 16 deadline to ensure all final rules incorporate the highest level of food safety to protect consumers in ways practical and efficient for industry members across the supply chain.
Tom O’Brien is the Washington, D.C., representative of the Newark, Del.-based Produce Marketing Association.
What's your take? Leave a comment and tell us your opinion.