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from being overwhelmed with test results that fail to call attention to real or potential food safety problems. The waiver must be issued through regulations, suggesting this authority is not meant to be a case-by-case waiver. FSMA does include a specific requirement for FDA to review testing by accredited state or local government laboratories if the results led the state to order a food recall. The review would be for the purpose to determine whether a national recall is warranted, or if FDA needs to take other compliance or enforcement actions. Food emergency response network While not a part of the accreditation program, Section 202(b) of FSMA requires FDA to report biennially on the implementation of a Food Emergency Response Network. This network is intended to provide surveillance, rapid detection, and surge capacity in cases of a bioterrorism attack on the food supply or other large-scale food-related emergency. Final issuance of the rule FSMA set a deadline of Jan. 4, 2013, for establishing the accreditation program with a requirement to use accredited laboratories, beginning six months later. FDA missed the statutory deadline. Presently, it is unclear when the program will start. What does this rule mean for consumers? Testing doesn't make food safe; food safety programs, processes, and associated verifications drive quality and safety of food production. Verifications often include testing; but finished product pathogen testing is rarely a meaningful avenue of verification. This discrepancy may be due to the inadequacy of population sampling, as it relates to a very low incidence of the defect (i.e., pathogen) meant to be detected. FSMA has given FDA more tools to regulate the foods under FDA's purview, making the agency more robust. It is anticipated that this approach will lead to fewer outbreaks, illnesses, and deaths attributable to foodborne pathogens in the U.S. Having the ability to establish, implement and oversee laboratory accreditation guidelines, as well as broaden domestic and foreign laboratory capacity, will support more efficient production of reliable data, and therefore, support FDA's efforts to protect public health. What does this mean for food safety professionals? Placing greater emphasis on laboratory expectations, including third-party accreditation, quality programs, technical competence, and use of validated methods allows for more clarity, and thereby, improved consistency across the industry in producing reliable data. Since FSMA currently applies to regulatory testing, commercial labs may or may not choose to implement such practices on all testing conducted at the facility, since testing would still be voluntary. Ideally, companies performing and/or requesting food testing to support important decisions about their process and products, including compliance with regulatory and global quality standards, demonstrate the value of providing specific laboratory expectations and for laboratory accreditation across the industry. ACKNOWLEDGMENTS The authors are grateful for the advice, assistance and contributions of Caroline Smith DeWaal, and our fellow IAFP Food Law Professional Development Group members. REFERENCES 1. Analytical Laboratory Accreditation Criteria Committee of AOAC International. 2010. Guidelines for Laboratories Performing Microbiological and Chemical Analyses of Food and Pharmaceuticals. AOAC International, Gaithersburg, MD. 2. Centers for Disease Control and Prevention (CDC). 2013. CDC Estimates of Foodborne Illness in the United States. Available at: http://www.cdc.gov/foodborneburden/ estimates-overview.html. Accessed 26 October 2013. 3. U.S. Department of Agriculture Food Safety and Inspection Service. 2013. Establishment Guidance for the Selection of a Commercial or Private Microbiological Testing Laboratory. Available at: http://www.fsis.usda.gov/ wps/wcm/connect/464a4827-0c9a-42688651-b417bb6bba51/Guidance-SelectionCommercial-Private-Microbiological-Testinglab-062013.pdf?MOD=AJPERES. Accessed 26 October 2013. 4. U.S. Food and Drug Administration Office of Regulatory Affairs. 1 January 2013 Revision. ORA Laboratory Manual, Section 7 - Private Laboratory Guidance. Available at: http:// www.fda.gov/downloads/ScienceResearch/ FieldScience/LaboratoryManual/ UCM092191.pdf. Accessed 26 October 2013. About the Authors Vanessa Coffman is Education Manager at STOP Foodborne Illness. 48 Food Protection Trends David W. Plunkett, JD, JM is Senior Staff Attorney for the Food Safety Program at the Center for Science in the Public Interest. January/February George Wilson is the Director of Business Development & Marketing for Invisible Sentinel. Wendy Warren, Ph.D. is Vice President of Government & Regulatory Affairs at AEGIS Food Testing Laboratories, Inc. http://www.fda.gov/downloads/ScienceResearch/FieldScience/LaboratoryManual/UCM092191.pdf http://www.fda.gov/downloads/ScienceResearch/FieldScience/LaboratoryManual/UCM092191.pdf http://www.fsis.usda.gov/wps/wcm/connect/464a4827-0c9a-4268-8651-b417bb6bba51/Guidance-Selection-Commercial-Private-Microbiological-Testing-lab-062013.pdf?MOD=AJPERES http://www.fsis.usda.gov/wps/wcm/connect/464a4827-0c9a-4268-8651-b417bb6bba51/Guidance-Selection-Commercial-Private-Microbiological-Testing-lab-062013.pdf?MOD=AJPERES http://www.fda.gov/downloads/ScienceResearch/FieldScience/LaboratoryManual/UCM092191.pdf http://www.fsis.usda.gov/wps/wcm/connect/464a4827-0c9a-4268-8651-b417bb6bba51/Guidance-Selection-Commercial-Private-Microbiological-Testing-lab-062013.pdf?MOD=AJPERES http://www.cdc.gov/foodborneburden/estimates-overview.html http://www.cdc.gov/foodborneburden/estimates-overview.html

Table of Contents for the Digital Edition of Food Protection Trends - January/February 2014

Food Protection Trends - January/February 2014
Contents
Economically Motivated Adulteration of Honey: Quality Control Vulnerabilities in the International Honey Market
Efficacy of Quaternary Ammonium Compounds on Different Conveyor Chips Contaminated with Poultry Rinsate
What Implications Does a Baseline of Self-efficacy of Food Safety in Adolescent Populations Have for Future Food Safety Education Interventions?
Food Safety Risks in Restaurants and School Foodservice Establishments: Health Inspection Reports
INOFOOD 2013 Conference & Expo
The 3rd Asia Pacific International Conference on Food Safety
China International Food Safety & Quality Conference (CIFSQ) + Expo
Dubai International Food Safety Conference (DIFSC)
Beyond the Bio
FSMA: Article 7
PDG
Industry Products
Coming Events

Food Protection Trends - January/February 2014