December 6, 2019

PMA makes recommendations for FDA’s ‘New Era of Smarter Food Safety’

The Food & Drug Administration (FDA) held a public meeting Oct. 21 to solicit feedback from stakeholders regarding a “New Era of Smarter Food Safety.” Topics of interest included traceability, evolving business models, preventive controls and food safety culture.

Highlights of the Produce Marketing Association (PMA) comments included appreciation and acknowledgement of FDA’s effort to engage broad stakeholder segment communities in a platform to identify and discuss roadblocks, solutions, as well as new and emerging technologies consistent with sensible and practical expectations in informing and protecting public health.

PMA strongly encouraged FDA to adapt a supply chain-wide traceability system that utilizes the existing industry standards, GS1 standards, more specifically, we support industrywide adoption of systems and approaches that capture and store the Global Trade Item Number (GTIN). Gaps in traceability components across the more fragmented links in the supply chain, noted in many outbreak investigations make timely and responsive communication more difficult and too often inconclusive. Likewise, PMA encouraged FDA, CDC and state regulators to upgrade and adopt new, compatible electronic databases and technologies that can easily share information.

PMA strongly supports the expansion of Rapid Response Teams (RRT) and include assistance to growers and handlers in conducting skill-appropriate root cause analysis (RCA). PMA also expressed the view that FDA seriously consider establishing a vetted expert network, a mechanism already available to and used by the FDA. This network would be a resource adjunct to any expansion of funding for the Rapid Response Teams (RRTs), as previously recommended by United Fresh and PMA.

PMA supports and encourages FDA to lead with its strength in areas the industry and general research community investigators cannot. FDA has a unique capacity to develop a high-resolution open genomic database for geographically diverse environmental index, pathogenic, and parasitic microorganisms. Characterizing and understanding the genomic diversity of individual isolates and broader microbiome and metagenomic profiles, combined with GIS layering and the role of regional edaphic and seasonality factors, is an area that FDA should undertake to expand its current efforts to promote and support the use of smarter tools for prevention. One benefit of this more complete view of genomic diversity and plasticity will be a greater level of precision in hypothesis generation during an emerging outbreak.

PMA encouraged FDA to continue to keep the “Educate as they regulate” mindset as they move forward with more regulatory oversight. The decision to provide inspectors “discretion” in several areas of enforcement of compliance has demonstrated real actions towards a Smarter Era of Food Safety by the agency. It showed the industry that FDA recognized the need of a learning curve to implement the new FSMA rules.

Romaine Lettuce E. coli O157:H7 Outbreak

On Dec. 3, the FDA and CDC released updates regarding the romaine lettuce E. coli O157:H7 outbreak. There has been a jump in illness from 67 to 102 and has expanded geographically from 19 states to 23. The latest illness onset date is Nov. 18, whereas the original advisory was issued on Nov. 22 following an earlier USDA recall notification on Nov. 21.

It is important to be clear in our communications that these updates, so far, are providing information on those cases working their way through the public health notification and reporting process, which is a normal delay of the system.

This most recent update does not identify any new cases with an illnesses onset date known to CDC or FDA after the advisory was announced. The first public notifications identified product labeled with a printed “Best By..” label expiration of Oct. 31. The Salinas regional district is several weeks past harvest of romaine lettuce and growers and shippers have informed us that any last minor standing fields scheduled for late harvest at the time of the romaine-specific regional source advisory were destroyed.

Partnership for Food Safety Education

In this live Q&A event, our very own Trevor V. Suslow and Jennifer McEntire from the United Fresh Produce Association will answer questions from health and food safety consumer educators about the current E. coli O157:H7 outbreak associated with romaine lettuce from Salinas. After a short overview on the outbreak, they will answer questions about labeling of bagged lettuce and how you can help to support consumers using consumer advice from the FDA and CDC. The event is hosted by the non-profit Partnership for Food Safety Education which both PMA and United Fresh are Contributing Partners. The webinar was recorded and will be posted on the PFSE website.

2020 Sneak Peek of Webinar Line-up

PMA has developed a new 30 minute webinar format which will highlight a series of informative, popular topics in an upcoming series called “U Need to Know.” These webinars will be scheduled to occur twice a quarter. We are always looking for topic suggestions. Feel free to reach out to Jill Dunlop with your ideas.

Current lineup includes:

  • FSMA Face-lifts for Legacy Facilities
  • Biological Soil Amendments & FSMA
  • Quick brain-lift on Whole Genome Sequencing
  • Are nanobubbles real and do they help?
  • What is Clean?
  • Sustainable Films and Packaging
  • Top Produce Picks for your Healthy Gut Microbiome

GFSI Technical Working Group

Trevor Suslow has accepted membership in the newly formed GFSI Managing risks in produce and leafy greens Technical Working Group (TWG) member. The GFSI Technical Working Group is convened to provide an objective review of best practices in the production and postharvest management of leafy greens around the world in response to food safety issues in this industry sector. It will also integrate the continuing the work the GFSI Task Force on a risk-based approach to managing and auditing primary production sites.

— Produce Marketing Association 

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