IWLA Seeks Changes in Animal Food Safety Guidelines

The commentary filing with the FDA raises two issues regarding supply chain responsibilities in the Food Safety Modernization Act.

The Food Safety Modernization Act’s core purpose is to keep the food supply safe through best practices in manufacturing, preventative controls and safety audits, but the International Warehouse Logistics Association (IWLA) believes the law can be improved. It filed comments last week seeking changes to a proposed rule to establish Current Good Manufacturing Practice (CGMP) and Hazard Analysis and Risk-based Preventive Controls on Food for Animals.  

Although the IWLA supports the FSMA's core purpose, it feels the new measures don’t account for distinctive characteristics of Association members who are warehouse-based third-party logistics providers. The commentary filing cites issues related to the roles and responsibilities between the food product owner and warehouse, characterizing these sections as misleading .

The first issue seeks to clarify the meaning of “solely engaged” in the storage of packaged food. This means that a warehouse storing consumer electronics, in addition to unexposed packaged food products, could still be considered “solely” engaged in the storage of packaged food.

“A typical 3PL warehouse maintains up to 400,000 square feet or more of space designed for multiple customers with a range of different products,” IWLA states, adding that “solely engaged in the storage of packaged food” should be intended to refer only to those activities in the warehouse that trigger registration under the FSMA. They do not refer to any nonfood activities that are outside the scope of FSMA.

The second issue applies to the responsibility for determining time and temperature controls. The current rule states that it is "rare" for warehouse operators not to have information on whether temperature controls are required and what specific temperature controls are necessary.

“In fact,” IWLA states, “it is rare for the 3PL to have sufficient information to determine this. The FDA does not serve the goals of food safety by placing this responsibility on a party that is not in a position to make a substantive determination about the temperature control needs of a product.” 

IWLA recommends that the FDA insist that the responsibility for this determination be placed on the product owner, which they say is in the best position to know product characteristics.

“The agency should require this information to be passed to supply chain participants who store the food," concluded IWLA Washington Representative Pat O'Connor.


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