A New Era of Smarter Food Safety; Public Meeting

Dear Sir or Madam: The American Frozen Food Institute (AFFI) appreciates the opportunity to share with FDA our perspective on opportunities for the agency to modernize its protection of the food supply and begin a New Era of Smarter Food Safety. 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 throughout the food distribution chain, including food producers, distributors, and retailers. AFFI and its members have a long history of advancing science and technology to achieve public health benefits, and we applaud FDA for proactively identifying the ways it can use new and emerging technologies and other tools to advance food safety. Executive Summary Common among our comments in these areas are three key themes we consider fundamental as FDA prepares its blueprint for the New Era of Smarter Food Safety: focusing on prevention; relying upon sound science to inform a risk-based approach; and enhancing transparency. 1.Prevention: Food safety is of preeminent importance to AFFI and our members. We supported the passage of the FDA Food Safety Modernization Act (FSMA), and our members have been working hard to implement the new regulations and enhance their food safety practices. As FDA's goal with the New Era of Smarter Food Safety is to build on the agency's efforts to implement FSMA, we believe that FSMA's focuspreventionshould remain central to the agency's efforts to modernize its approach to food safety oversight. 2.Reliance on science to inform a risk-based approach: Like the agency's FSMA regulations, FDA's blueprint for the New Era of Smarter Food Safety should rely on sound, risk-based science. We encourage FDA to use existing and forthcoming science to inform the agency's forthcoming policies and initiatives and help ensure that the New Era of Smarter Food Safety is risk-based. 3.Transparency: Central to any food safety initiative is effective communication among regulators, industry, and consumers. As FDA moves forward in implementing the New Era of Smarter Food Safety, we encourage the agency to ensure it effectively communicates its actions and goals to the public. The agency also should consider opportunities to facilitate an open dialog with industry to enable further collaboration between FDA and industry. Finally, when FDA and industry communicate with consumers, particularly regarding foodborne illness outbreaks, they need to clearly communicate to consumers the risk presented and the action steps they should take to protect themselves. Please attached for AFFI's full comment letter. Respectfully submitted, Donna M. Garren, Ph.D. Executive Vice President, Science and Policy