National Fisheries Institute Statement on FDA Food Traceability Proposed Rule
WASHINGTON, DC September 22, 2020 — The Food and Drug Administration (FDA) has released its proposed rule for traceability and recordkeeping, along with a draft “Food Traceability List” that catalogues which products would be subject to the requirements.
The National Fisheries Institute (NFI) supports efforts to both modernize and advance food safety. The seafood community has been at the forefront of efforts to safeguard our safe and wholesome products as an early adapter of the Hazard Analysis and Critical Control Point (HACCP) system. This year, as the FDA moves towards an evolution in traceability, NFI’s members have proactively explored technologically enabled traceability through a Blockchain pilot to test its viability in a real seafood value chain.
We are currently reviewing the proposed rule and draft “Food Traceability List.” And as with any new regulatory structure, we are interested in ensuring there are no duplicative systems that would complicate the new traceability parameters.
An initial review of the draft “Food Traceability List,” from a seafood perspective, suggests a “one size fits all” approach; which may not be warranted. Just like with HACCP and other modern food safety efforts, a focus on a few critical points or products is a better use of energy and resources.
We are hopeful this proposal will help begin an orderly process that integrates modern supply chain traceability systems within a technologically advanced regulatory structure.