Michael Taylor of the FDA gave a notable speech in London to the Global Food Safety Conference.
From my quick time evaluation of what he said, it is apparent the FDA has been thinking long and hard about the import provisions of the food safety law.
One opening graph spelled out this "loud and clear" intent:
"And I want to convey today one message loud and clear:
"The FDA Food Safety Modernization Act only heightens the imperative that we in the United States work in partnership with the global food safety community to meet the public’s high expectations for the safety of food, no matter its origin."
TK: What does that exactly mean? The U.S. will link hands with the capabilities of foreign governments? The FDA will rely on third party inspectors and auditing companies? Help us figure this out?
Probably all of the above.
Taylor used the phrase "carrying coals to Newcastle" in his thoughts of speaking to the food safety group about the global food safety system, the importance of third party auditors and the importance of integrating food safety into supply chain management.
Wait, you interject; what does carrying coals to Newcastle mean? Basically, to do something
To do something "pointless and superfluous." You wouldn't carry coals to Newcastle since there is much coal there already. Savvy?
"Carrying coals to Newcastle" and the meaning is somewhat akin to "preaching to the choir," a metaphor which Taylor later used.
These guys in the London conference know all about these topics. It is the rest of us that have some catching up to do....
Taylor's speech had a few interesting nuggets, primarily related to potentially expanded roles for third party inspectors and auditors. Here are a few select quotes:
"We also know that the food safety challenge and food safety solutions have to be understood and addressed globally, which is why and our new food safety law establishes a new paradigm for FDA’s oversight of imported food.
In fact, the globalization of the food supply was a major force driving passage of the Food Safety Modernization Act.
Consider just a few numbers: 15 percent of the entire U.S. food supply is imported, including about 50 percent of our fresh fruits, 20 percent of our vegetables, and 80 percent of our seafood.
It is for these reasons – high public expectations and expanding trade in food – that the effort to improve food safety and to build prevention in from farm to table is a global movement…and is good business."
TK: Especially good business for third party inspectors and auditors, I might add. Taylor later talks about the role of third-party inspectors...
"The key, however, is that the new law explicitly places primary responsibility for food safety – for prevention – on food producers and processors.
Think of it as supply chain management written into law."
TK: Later, Taylor continues...
"The new importer accountability provisions require importers to implement a foreign supplier verification program.
They will need to provide adequate assurance that imported foods have been produced under appropriate risk-based preventive controls that provide the same level of public health protection as those required of our domestic food industry.
This clarification and strengthening of the importer’s responsibility for food safety is the centerpiece of the new law’s import safety reform, but it is not the only thing.
Leveraging resources and preventing problems are also the guiding principles for an element of the new law that is no doubt of great interest to many of you here today. Namely, accredited third-party certification – which we see playing a crucial role in providing the assurances we all seek about the safety of globally-traded food.
Under the new law, we are charged with establishing a system for accrediting third-party auditors of foreign food facilities – auditors who can certify a firm’s or a facility’s compliance with U.S. standards with rigor, objectivity and transparency…and on whom FDA can rely as part of the food safety assurance system.
That is a tall order, but we intend to meet it.
And there will be plenty of issues, since the new law envisions multiple roles for third-party certification.
The first is to help importers meet their new responsibility to verify that the food they import into the United States is in compliance with U.S. standards. Some importing firms have integrated robust food safety verification procedures into their supply chain management systems and will likely be able to fulfill their verification responsibility on their own.
Others have not and may want to rely in whole or in part on the certifications of third-party auditors.
In either case, the critical issue is ensuring importers have the means to verify that their suppliers have systems in place to produce safe food.
Second, importers participating in the new law’s voluntary program for expediting the importation of food into the U.S. must accompany their food shipments with safety certifications. We expect that many companies will seek to participate in this program, and we must have an accredited third-party certification program in place to meet that demand.
Finally, FDA can require an accredited third-party certification as a prerequisite for the importation of high-risk foods into the U.S., and we will be prepared to do this when we believe it necessary to protect the health of our consumers.
So, you can see that we envision accredited third-party certification playing a vital role in our future food safety system.
You could say our goal is both straightforward and herculean:
A prevention-oriented, risk-based food safety system that protects our consumers from avoidable harm while preserving their access to the wide array of food choices made possible by today’s global food marketplace.
If we can do that, you may be thinking, maybe we can also do something about the weather."
TK: Taylor is talking blue sky, food safety regulations in the global context in a way that wasn't unpleasing to his audience. Messy details about how much this will cost the industry and how much man hours will be required haven't yet been unveiled. Indeed, as with Taylor's weather reference, it is the calm before the storm.