Getting Food Safety and Security Right

Nothing is more important to public safety than making sure that our food and food supply chain are safe and secure. Congress recognized this when early last year it passed the 2011 Food Safety Modernization Act, designed primarily to address safety and security concerns primarily in food manufacturing operations.

To develop the compliance programs and regulations that will implement the new act, the U.S. Food and Drug Administration has reached out to its partners in the food industry for input. IWLA has participated both as a member of an industry coalition addressing this matter, and with our own comments submitted to the FDA last month.

It is expected that the FDA will issue a proposed rulemaking on or near January 4 dealing with many of these issues.

The question always has been: How do we protect America’s food supply most effectively with the limited economic and staff resources available to the government? Congress recognized this as a real issue when it wrote the law by including a provision that specifically grants the FDA authority to make exceptions where additional regulations would be redundant and do nothing to advance the cause of safety.

In recognition of this, the International Warehouse Logistics Association has asked the FDA to recognize in its new rules implementing the new law’s hazard analysis and preventive controls provisions that many third-party warehouse operations do not expose packaged goods to the environment. IWLA believes that facilities solely engaged in the storage of packaged foods not exposed to the environment can be satisfied through compliance with current regulations and other stringent industry standards.

Our concern, like FDA’s is total public safety in the food supply chain. We welcome the FDA’s attention to detail and only ask they 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.

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 would burden both the FDA and warehouse operators with significant costs and administrative burdens without supplying any corresponding benefit to the improvement of public health.

In recent years the news media has been filled with stories about recalls due to food-related disease. However, no food-borne illness outbreaks have been reported due to improper handling by commercial warehouses. Research has shown that there have been no significant food-borne illness outbreaks attributable to the storage of packaged goods not exposed to the environment at such facilities.

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

Our members also comply with other FDA regulations that should be sufficient to answer any concerns in this regard, including the requirements of the Bioterrorism Preparedness and Response Act of 2002, and the current Good Manufacturing Practices (cGMP) applicable to food security.

In addition, IWLA members are required to comply with extensive 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.

IWLA warehouse members also routinely implement a full range of standard operating procedures related to the safety and security of the food products they handle. They are typically certified by either the American Institute of Baking or the American Institute of Sanitation. Many also are certified by the International Organization for Standards.

While the product is in the facility, the warehouse conducts weekly and/or monthly inspections -- depending on customers’ requirements -- of all products to ensure they are in usable condition and there are no signs of tampering, significant visible damage, adulteration or pest infestation. Inbound and outbound goods are inspected in the same manner.

The few hazards that may arise in such storage facilities, including those relating to environmental, climate, and pest controls, are already addressed under FDA’s existing regulations and enforcement regime

During last October’s Washington, DC Fly-In, IWLA members attending heard an informational presentation by Sharon Mayl, Senior Advisor for Food Policy at the FDA, about the progress the agency was making in developing programs and rules to implement the new law.

Mayl noted that the agency was actively engaging with stakeholders to help determine reasonable and practical ways to implement the law’s provisions. The FDA needs this help from private industry because of the challenges it currently faces with an enormous workload consisting of 50 new rules, guidance documents and reports, all of which are due in three years.

The members of IWLA stand ready to help the FDA in any way we can to ensure this process is both efficient and effective that can be developed. We are dedicated to making sure the nation’s food supply is the safest and most secure it can be when it is in our hands.