Bioterrorism Preparedness; Registration of Food Facilities

The American Frozen Food Institute (AFFI) appreciates the opportunity to provide comments to the Food and Drug Administration (FDA) regarding its proposed rule to amend the food facility registration requirements. As the voice of the U.S. frozen food industry, AFFI is the national trade association that represents the interests of all segments of the frozen food industry. AFFI members manufacture and distribute frozen foods throughout the United States and globally. AFFI represents a broad group of companies that are required to register with FDA. FDA is proposing to amend the agencys facility registration regulations as part of implementation of the FDA Food Safety Modernization Act (FSMA) and to enhance the agencys capabilities to respond to food safety issues. We support FDAs goal of improving the utility of the food facility registration database so that the agency can better use the information to focus use of its limited inspection resources. However, we are concerned that some of the proposed revisions would impose unnecessary burdens on industry without supporting that goal. Accordingly, we recommend that FDA reconsider its proposals to (1) require submission of Dun & Bradstreet Data Universal Numbering System (D-U-N-S) numbers, (2) require owners, operators, or agents in charge to provide email verification of registrations, (3) specify the types of activities conducted at the facility, and (4) initiate cancelation unilaterally. These issues are discussed in more detail in the comments that are attached.