Draft Guidance for Industry on Voluntary Third-Party Certification Programs for Foods and Feeds; Availability

GMA appreciates the opportunity to comment on the revised FDA Guidance for industry on voluntarily third-party certification programs and looks forward to working closely with the agency as the various elements are introduced into the program. A safe and secure global food supply chain is essential to protecting consumers and is a top priority for GMA. GMA fully supports the opportunity for FDA to utilize the results of commercial third party audits submitted voluntary by a domestic manufacturer or by an exporter of food products to the U.S. to help FDA make better informed decisions, especially for the purpose of enhancing the trade and import process. As noted previously, GMA members do not agree with any language or program that makes a third party certification program appear to be "quasi-government" or a surrogate for FDA or any other regulatory inspection activity. The program established should be a voluntary program that allows an establishment the option to provide all certification documentation to FDA or other regulatory agency for the purpose of expediting importation and/or building confidence with an agency. FDA must work with other foreign government agencies to establish equivalent standards and oversight. It is crucial that FDA provide leadership and establish partnerships with other governments to gain consensus throughout this process.