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FDANonrulemakingFDA-2025-N-1733

Tool for the Prioritization of Food Chemicals for Post-Market Assessment

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American Frozen Food Institute filings
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American Frozen Food Institute filed 1 comment on this docket between Aug 19, 2025 and Aug 19, 2025. 32 other organizations filed here. The comment window closed 344d ago.

What American Frozen Food Institute filed (1)

Aug 19, 2025· Comment from American Frozen Food Institute· FDA-2025-N-1733-0074

The American Frozen Food Institute (AFFI) appreciates the opportunity to comment on the Food and Drug Administration's ("FDA" or "Agency") Tool for the Prioritization of Food Chemicals for Risk Assessment (Prioritization Tool). From manufacturers to distributors to suppliers to packagers, AFFI is proud to represent publicly traded and family-owned companies who help produce frozen foods and beverages for today's food service and retail marketplace and serve as economic pillars within their communities. Throughout the U.S., frozen food sales reached $85 billion in the last year, and the industry accounts for 670,000 U.S. jobs. In addition to our members' strong role in economic growth, AFFI members share a commitment to food safety and ensuring consumer confidence in the food supply. AFFI recognizes and appreciates FDA's efforts to develop an enhanced systematic process for the post-market assessment of chemicals in food. AFFI believes that a methodical approach to post-market assessments will further strengthen consumer confidence in the food supply while minimizing confusion caused by the growing patchwork of state-by-state legislative attempts to address ingredient safety. As the U.S. authority on food safety and public health, FDA is the appropriate body to be at the head of creating this comprehensive approach. AFFI provided comments on the Discussion Paper FDA published in August and is incorporating those comments by reference with this response (Document ID FDA-2024-N-3609-62519). Although we support components of the Prioritization Tool, we have identified opportunities for further refinement, additional information, or adjustment. To that end, we offer the following comments as FDA works toward finalizing the Prioritization Tool and implementing the enhanced systematic process: The Prioritization Tool is not appropriate for evaluating unintentionally added substances. If FDA concludes the Prioritization Tool will apply to unintentional substances and raw commodities, the "Public Health Criteria" should be refined to ensure science-based prioritization outcomes. FDA should revise the approach to defining, scoring, and weighting the "Other Decisional Criteria" to ensure the Prioritization Tool adequately balances the potential science-based food safety risks presented by a chemical, with the need to ensure public trust in the food supply. FDA should reopen the comment period for the Prioritization Tool once additional details regarding the post-market assessment framework are made public. We expand on these points in the detailed comments that are attached.

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