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Over the past year and a half, outbreaks related to fresh pro- duce have called into ques- tion the industry’s ability to trace products, and triggered
consumer groups to question why the FDA hasn’t acted on the authority Congress granted through the Food Safety Modern- ization Act to require the food industry to improve traceability.
Yes, Section 204 of FSMA does give the FDA the authority to require companies to keep additional (traceability-related) records for “high-risk foods.” At rst glance, it may seem reasonable to only ask portions of the industry — those that have had issues — to up their game. But upon further evaluation, the concept is fraught with challenges, and the term “high risk” will do more to scare consumers away from healthful products than it will to protect them. Further, the FDA and the industry will waste time and energy arguing over the list, at the expense of making true gains in improving traceability.
The need to trace implicated foods back to the source of contamination and forward to all other potentially contaminated foods can occur in any commodity, regardless of prior linkage to foodborne outbreaks. This has been demonstrated time and again in produce (e.g., cucumber, celery, papaya and sweet peas) as well as non-produce commodities that are linked to foodborne outbreaks for the rst time and must be traced effectively. “Risk” is based on handling practices, not commodity. If the FDA published a list of “high risk foods” and limited improved traceability to this subset, it surely would become outdated as new outbreak vehicles emerge, and we would nd ourselves stumbling to trace these “low-risk” items.
Our greatest concern for fresh produce stems from the fact that we need to
6 / SEP TEMBER 2019 / PRODUCE BUSINESS
High Risk Foods’ Term Distracts From True Progress On Traceability
BY JENNIFER MCENTIRE, PH.D., VICE PRESIDENT OF FOOD SAFETY & TECHNOLOGY FOR UNITED FRESH PRODUCE ASSOCIATION
encourage consumers to eat more of these healthful products. Fresh produce items labeled “high risk” will incur reputational damage that discourages consumption. Designating entire commodity groups as high risk would have the consequence of damaging consumer con dence and dooming efforts by any company included in that designation to demonstrate the safety and reduced risks of their food safety practices. Once being designated as “high risk,” there is no obvious mechanism by which a food can be removed from the list. And even if it were removed, it would be dif cult, if not impossible, for consumers to forget.
There is no question that traceability practices within the fresh produce supply chain (and for that matter, across the entire food industry) must rapidly modernize. More than a decade ago United Fresh, in collaboration with the PMA, CPMA, and later GS1 US, launched the Produce Trace- ability Initiative (PTI), advocating for the
use of electronic systems and globally stan- dardized data to provide rapid and accurate traceability information. Today, the majority of cases of fresh produce bear a PTI label — but this critical traceability information is not captured as produce moves through the supply chain. We encourage FDA to use its authority to close these gaps. Although implementation could be prioritized for certain products or commodities, this can be done without terming these products “high risk.”
The clock is ticking to make an adjust- ment to the “high-risk” approach, or at least to this term. As part of a consent decree stemming from a lawsuit brought by a consumer group, the FDA has committed to proposing a list of high-risk foods in September 2020. Thankfully, the agency seems open to considering alternate terms that better re ect the situation: fresh produce needs to be traceable from the retail or restaurant location back to the source.