As a result of the traceback pilot projects authorized by the Food Safety Modernization Act, the Institute of Food Technologists, which conducted the projects, formally listed 10 recommendations to the Food and Drug Administration. The recommendations are as follows:
1. From an overarching perspective, IFT recommends that FDA establish a uniform set of recordkeeping requirements for all FDA-regulated foods and not permit exemptions to recordkeeping requirements based on risk classification.
2. FDA should require firms that manufacture, process, pack, transport, distribute, receive, hold, or import food to identify and maintain records of CTEs (critical tracking events) and KDEs (key data elements) as determined by FDA.
3. Each member of the food supply chain should be required to develop, document, and exercise a product tracing plan.
4. FDA should encourage current industry led initiatives and issue an Advance Notice of Proposed Rulemaking or use other similar mechanisms to seek stakeholder input.
5. FDA should clearly and more consistently articulate and communicate to industry the information it needs to conduct product tracing investigations.
6. FDA should develop standardized electronic mechanisms for the reporting and acquiring of CTEs and KDEs during product tracing investigations.
7. FDA should accept summarized CTE and KDE data that are submitted through standardized reporting mechanisms and initiate investigations based on such data.
8. If available, FDA should request more than one level of tracing data.
9. FDA should consider adopting a technology platform that would allow efficient aggregation and analysis of data submitted in response to a request from regulatory officials. The technology platform should be accessible to other regulatory entities.
10. FDA should coordinate traceback investigations and develop response protocols between state and local health and regulatory agencies, using existing commissioning and credentialing processes. In addition, FDA should formalize the use of industry subject matter experts in product tracing investigations.
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