IWLA Seeks Exclusion for 3PLs from FDA Act

As the U.S. Food and Drug Administration (FDA) writes regulations to implement the Hazard Analysis and Preventive Controls Provisions of the 2011 Food Safety Modernization Act, the International Warehouse Logistics Association (IWLA) is offering a suggestion: officially recognize that many third-party logistics (3PL) warehouse operations do not expose packaged goods to the environment.

This act was intended by Congress to address safety and security concerns primarily in food-manufacturing operations. IWLA wants an exception for 3PLs to the requirement that food facilities conduct a hazard analysis and implement risk-based preventive controls to address food-safety hazards. IWLA says 3PL warehouses would continue to observe and be subject to many other regulations designed to protect the U.S. food supply.

"Our concern, like FDA's, is total public safety in the food supply chain," said IWLA President & CEO Joel Anderson. "We welcome the FDA's attention to detail and ask that it equally recognize that when packaged goods in a warehouse are not exposed to the environment—not opened, damaged, or otherwise potentially contaminated—there is no chance of contamination at the warehouse."

Anderson added, "Imposing extensive hazard-analysis and preventive-controls requirements on warehouse facilities solely engaged in the storage of packaged foods that are not exposed to the environment creates significant costs and administrative burdens without a corresponding benefit to public health."

Food products stored in food-grade warehouses operated by IWLA members are typically stored in sealed packages or containers – often in pallet-sized increments – and not exposed to the environment, the association told the agency.

In addition, IWLA members are required to comply with the preventive controls mandated by their customers, which typically include standards for temperature control, proper storage, and other exacting requirements. "3PL warehouses work closely with the manufacturer to understand the nature of the food products themselves and the conditions under which they must be held for optimum quality and safety," the IWLA communication to the FDA reads.

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