Food Safety FOMO- updates for the food safety community

5/18/2023- Hello and welcome to the first ‘issue’ of Food Safety FOMO. When I was with the United Fresh Produce Association, I had the privilege of keeping produce industry members informed about issues relevant to them- a list of super short descriptions with hyperlinks and usually flavored with a little perspective. Now that I’ve moved to the consulting world, I want to keep up myself, and decided to share what I’m looking at with the broader food safety community. It’s usually ~2 weeks before enough accumulates to hit ‘send’. I'll keep playing with formatting- that's not my forte!

1. Mistakes happen, and this was a big one—Lef Farms issued a recall based on a state test result for a pathogen that was later determined to be lab error.

• If you’re wondering about state testing programs, this is part of an FDA funded program called the “Laboratory Flexible Funding Model” ostensibly aimed at building technical lab capacity in states. States work with FDA to identify product/hazard pairs they will test, but there is remarkably little public information available, and discouragingly, no plan to share data (what was tested, how many positive, negative, etc). This is a real missed opportunity to learn from surveillance testing.

2. There’s a Partnership for Food Protection co-led by AFDO and FDA that consists primarily of regulators (local, state, and federal) with various workgroups (including an industry assn workgroup). They recently released a recall toolkit to aid in communication between regulators during a recall.

3. FDA released a draft compliance policy guide on major food allergen labeling and cross contact (open for comment until 7/17). CPGs provide instruction to inspectors on what they should look for during inspections, so it’s a bit different of a perspective from guidance for industry.

• Other than now referencing sesame, it’s consistent with FDA’s previous position on allergens (including that advisory statements like ‘produced in a facility that...” are not substitutes for GMPs and Preventive Controls).

• It also identifies how FDA would evaluate the health hazard of an undeclared. Although FDA has not established a tolerance for any allergens, this suggests that FDA recognizes that risk varies.

4. Will standardized date labeling reduce food waste? Does food magically become unsafe when it passes a certain date? Congresswoman Pingree re-introduced a bill that would distinguish ‘discard’ from ‘quality’ related date labeling wording (an improvement over previous bills which more strongly suggested that food was unsafe after it’s “use by” date). I’ve followed this since at least 2015 and it’s never gone anywhere. Maybe this is the year?

5. Having written many reports on traceability for FDA while I was at IFT, I was surprised at the most recent IFT traceability ‘report’ FDA commissioned. It feels like they could have said more. Slide 14 on interoperability left me hungry for details (like, of the 14% most highly interoperable, are they commercially available or still in proof of concept?). I found the most interesting info in the appendix!

That’s it for my first blog post. Feedback is always welcome! Jennifer