4.6 Response

Tracebacks--NASDA strongly urges the immediate development and implementation of a uniform farm animal identification and tracking system, as well as systems that make possible the identification and tracking of domestic and imported food products.

The need for an ability to track crops, livestock and food products from farm to table cannot be overstated in terms of protecting public health and preserving the economic viability of the food and agriculture industry. Consumer and market demands have already begun driving trends to greater accountability and traceability. Increasing threats from a food safety and animal health perspective alone would be sufficient argument in favor of developing comprehensive product identification and tracking systems. Last summer Canada was, and now the United States is, under a global microscope as we struggle to trace the source of a cow infected with BSE as well as other animals associated with that cow. The specter of terrorist attacks makes the development and implementation of such systems even more imperative. If we require more than a few hours to locate all products associated with a terrorist incident, we risk a massive loss of consumer confidence in the nation’s food and agriculture system. That could have far costlier consequences than the immediate cost of the incident.

An effective preharvest quality assurance program should contain a feedback loop whereby food producers and food processors share relevant information on disease agents and disease incidences, diagnostic procedures and intervention strategies. The various segments of the industries can work together through an effective quality assurance program to identify and implement effective intervention strategies to achieve a safer food supply for consumers.

The Secretary should have some oversight of preharvest activities and authority to trace disease agents through all points of production to the place of origin, or at least to the last point of production. In order to make such tracing of organisms and agents possible, the Secretary should have the authority to require appropriate identification of individual animals and plant material. Such identification can lead to a more effective, rapid recall of potentially contaminated food products along the entire food chain, as well as minimization of illness and/or death resulting from exposure. Such a system also provides increased consumer confidence, while possibly minimizing the economic loss to industry in the event of a product recall. Plant records should identify the grower, and such identification could be coded.

Traceback of foods that are inapparent carriers of potential human pathogens should be for the purpose of developing ecological, epidemiological, diagnostic and intervention information and strategies. Quarantine of farms, however, is inappropriate for potential foodborne pathogens that have a number of host species, are found in the environment, and for which there are no effective preharvest diagnostic procedures or intervention strategies. Should quarantine authority become necessary it should continue to reside with state animal health agencies. Seizures/embargo authorization is necessary to halt the movement of adulterated products in commerce.

The federal government should work closely with state governments and industry to develop an identification system that will address the diversity of production, marketing and distribution mechanisms for fresh and processed food products.

It is also important for consumers and industry, as they move between states, to have the confidence that a consistent and uniform set of minimum standards exists that will ensure the safety of the food they serve and consume. This can be accomplished by having all states incorporate the FDA Model Food Code. The 1997 FDA Model Food Code is a document that provides scientifically based retail food safety advice for food regulatory agencies at all levels of government. It is a living document that will continue to be reviewed and updated on a regular basis through input from state and local food regulatory agencies, industry, academia, and consumers through such forums as the Conference for Food Protection and the Association of Food and Drug Officials. It has received endorsement from USDA, CDC, and various food industry organizations.

FDA Rapid Response Team and Infrastructure Development--NASDA believes FDA should expand the grant program to include additional states. This is the most efficient way to increase the Nation’s capability to rapidly identify and respond to a food safety issue. The grants provide not only training and exercising of RRT members, but also for infrastructure development necessary to support the teams.