Establishment-Specific Data Release Strategic Plan

The American Frozen Food Institute (AFFI) appreciates the opportunity to comment on the U.S. Department of Agriculture's (USDA's) Food Safety and Inspection Service's (FSIS's) sample dataset and documentation as part of the Establishment-Specific Data Release Strategic Plan. From manufacturers to distributors to suppliers to packagers, AFFI is proud to represent publicly traded and family-owned companies that help produce frozen foods and beverages for today's foodservice and retail marketplace and serve as economic pillars within their communities throughout the U.S. AFFI members share a commitment to transparently communicate information about the safety of the foods they produce and sell. AFFI supports the goal of increasing the transparency of federal regulatory activities. Transparency promotes accountability and fosters better-informed citizens. We appreciate FSIS taking steps to evaluate the agency's contribution to this goal. However, we caution FSIS that releasing information about regulated companies is only beneficial when it improves public understanding of federal regulations and the regulated industry. We are concerned that FSIS's plans for publishing whole genome sequence (WGS) identifiers will not provide the necessary context for the data, consequently causing public confusion and data misinterpretation. We offer several recommended changes to the overall objectives of the proposed data release. Please see additional comments attached.