ARLINGTON, VA. — The National Grain and Feed Association on May 25 submitted a statement to the U.S. Food and Drug Administration recommending that the agency make several changes to its draft guidance for industry titled “Foreign Supplier Verification Programs for Importers of Food for Humans and Animals.” The statement suggested how the F.D.A. might better inform importers on how they might comply with the import rules established under the Food Safety Modernization Act.
The N.G.F.A.’s statement also included recommendations on certain Foreign Supplier Verification Program (F.S.V.P.) issues that it said, if implemented, would result in meaningful reduction in regulatory burdens and costs on the regulated industry, while still enabling the F.D.A. to fulfill its public health mission and statutory obligations.
Among the recommendations made by the N.G.F.A. were that the F.D.A. should:
- Provide a more proactive system to inform entities when they have been named as the importer for purposes of the rule to avoid inaccurate or false designations that would create potential compliance obligations.
- Designate pulse raw agricultural commodities (e.g., dry peas, lentils, chickpeas, and dry beans) as “grain,” so that the agency’s previously announced enforcement discretion for certain importers of grain raw agricultural commodities intended for further processing would be appropriately extended to such commodities.
- Clarify that the agency intends to exercise enforcement discretion for animal food contact surfaces with regard to F.S.V.P. requirements.
- Limit the scope of potential economically motivated adulteration hazards that importers need to consider to those for which there has been a pattern of economic adulteration in the past.
- Update its web site to provide clearer and more concise information pertaining to countries the agency recognizes as having a food safety system that is comparable or equivalent to that of the United States.
