Should market channels be used as a basis for risk categorization?
If so, how?
Is there a need to consider market channels in risk categorization, considering that the statutory qualified exemption already addresses market channels as a possible risk factor?
Are other data or information available that would otherwise be useful in considering a commodity-specific approach?
Lest the FDA be accused of being out of touch, too prescriptive and all-knowing in its food safety rules, let it be remembered the dozens of question marks we find in the proposed regulations. Whether the industry has the time, resources and knowledge to answer them is yet another unanswered question.