A.M.I. comments on F.S.I.S. proposed rule
May 26, 2010
by Meat&Poultry staff
WASHINGTON — Comments regarding a Food Safety and Inspection Service (F.S.I.S.) proposed rule titled "Notification, Documentation and Recordkeeping Requirements for Inspected Establishments" have been filed by the American Meat Institute (A.M.I.).
In its comments, A.M.I. urges F.S.I.S. to include a de minimis exception in its final rule.
“The more practical approach would be for F.S.I.S. to follow the notification standard set forth in the Food and Drug Administration’s Reportable Food Registry,” according to A.M.I. “Following that precedent, notification would only be required if there is a reasonable probability that the use of, or exposure to, the article of food will cause serious adverse health consequences or death. Even if the agency elects to broaden the circumstances in which notification is required, the agency should, as part of a final rule, adopt a de minimis approach and provide examples of circumstances that agency officials believe meet that standard,” A.M.I. said.
The proposed rule also provides, among other things, that the establishment must notify F.S.I.S. of the “destination” of the adulterated or misbranded product. A.M.I. is asking F.S.I.S. to clarify either in the final rule or its preamble that establishments are required to provide information concerning their direct consignees to avoid confusion.
A.M.I. further notes the recall procedures section includes elements not authorized by the Farm Bill, which should be remedied. “That the proposal can require that a company have procedures in writing that articulate the steps a company will take to execute a recall is within the parameters of the Farm Bill language. The Farm Bill language does not, however, require plants to articulate the decision-making process that company officials follow in deciding whether a recall is warranted,” according to A.M.I.
A.M.I. also said in its statment, “The Farm Bill language and the proposed rule both provide that recall procedures should be developed and maintained for product “produced and shipped” by an establishment. The preamble to the proposed rule erroneously asserts that such procedures would be prepared and maintained for product “produced or shipped” by the establishment.
The final rule and its preamble need to be consistent with the statutory language that provides that recall procedures address instances in which product has been produced and shipped by the establishment, it concluded.
Click: http://www.meatami.com/ht/a/GetDocumentAction/i/59733 to read A.M.I.’s entire comments.