N.A.M.P. urges opposing draft validation guidance

by Bryan Salvage
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WASHINGTON – All U.S. processor members of the North American Meat Processors Association (N.A.M.P.) are being urged by the association to write Food Safety and Inspection Service (F.S.I.S.) Administrator Al Almanza and their Congressional representatives to oppose the F.S.I.S. draft guidance validation guidance document in its present form. On April 12, N.A.M.P. sent processor members a copy of the draft guidance document, a summary, and suggested language for their communications to Mr. Almanza and the Hill.

A coalition of industry associations, including N.A.M.P., had another meeting last Monday with Mr. Almanza and F.S.I.S. officials, and Mr. Almanza met with industry groups again on Wednesday in a regular monthly briefing. At Monday’s meeting, the coalition stressed it views this document as a fundamental policy change not merely a guidance, and that the document requires in-plant validation by microbiological testing for even the most basic and time-tested processes – and it imposes a cost burden on processors with no discernable food-safety benefit.

An extension on the comment period has been requested by N.A.M.P. and other industry associations. F.S.I.S. granted an extension until June 19, Mr. Almanza told the group on Wednesday.

Even though the comment period was extended, N.A.M.P. urged all its U.S. processor members to submit their comments now, and to alert their members of Congress about the significant adverse impact this proposed guidance could have on their cost of doing business with no known improvement to food safety.

“Companies should not have to validate that the sun rises in the East,” one coalition participant said after last Monday’s meeting.

The approach is unnecessarily broad in scope, and not focused on possible specific needs for in-plant validation. For example, companies would be required to validate by in-plant microbiological testing the cooking processes in Appendix A.

While N.A.M.P. opposes the draft guidance document, it does appreciate the willingness of F.S.I.S. to meet with N.A.M.P. and the coalition, to get the document out to industry informally for comment, and to listen to industry’s concerns. Although it is still early in the process, these actions by F.S.I.S. indicate industry’s feedback may have a constructive impact on FSIS decision-making.

F.S.I.S. is circulating the document informally to solicit stakeholder feedback before F.S.I.S. puts it into the formal Office of Management and Budget (O.M.B.)/Federal Register notice process.

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