28 March 2015
FDA speaks up about the state of seafood
While at Seafood Expo North America in Boston I went to the conference session “The Future of Seafood Regulations Post FSMA.” This was led by Benjamin England, the CEO of U.S. Food and Drug Administration's (FDA) Imports.com – an FDA consulting firm serving clients in over 90 countries with FDA regulatory and compliance services. England was joined by a panel consisting of Troy Petrillo, FDA/ORA Investigation Branch in the New England District Office supervisor with responsibility for import operations; Dominic Veneziano, FDA Director for the Division of Import Operations; Peter Koufopoulos, Director of the Division of Seafood Safety at FDA’s Center for Food Safety and Applied Nutrition; and Peter Quinter, Chair of the Customs and International Trade Law Group at the law firm of Gray Robinson.
All credit to them and FDA for putting themselves in front of industry – I cannot remember where this has happened in Australia, but we need more of it. Too many things happen behind closed doors without open and frank discussion, and we will not get continuous improvement without truth and transparency between all the main players in the game. At the end of the day, the whole industry cannot afford any let up on its food safety actions.
We learned about the logistical nightmare that confronts the FDA with the amount of seafood that has been imported – overall, more than 1 million lines of seafood out of 34-35 million lines of product – and how they go about the task ensuring the regulations are enforced. The line of regulation between FDA and Customs and Border Protection has been narrowing, and there is clearly more collaboration.
While the majority of the industry is doing the right thing, there is always an element of cutting corners and taking short term views. The industry can be slack on important food safety issues also. It cannot afford this, and what was evident from the figures that were presented by the FDA in the session is that there is definitely room for improvement.
In 2015, there was a 1,766 (1,501 in 2014) unique count of lines ‘refused’ from the 1,010,046 lines available (938,708 in 2014). From the total 3,914 samples that were taken (5,117 in 2014), 473 were rejected (361 in 2014), which equates to 12.1 percent (7.05 percent in 2014).The total number of violations in 2015 amounted to 814, or 20.8 percent (756 and 14.77 percent in 2014). The FDA had cut two days off the time taken from sample collection until final disposition – from 23 days in 2014 to 21 days in 2015.
They were able to give some updates for 2016 which highlighted similar figures to 2015, with the number of violations amounting to 312, the equivalent of 20.9 percent.
To get a good view of the session I took some photographs of the main items which you can view here:https://www.facebook.com/media/set/?set=oa.10153969159114512&type=1&hc_location=ufi
There are some confusing things about the rejections in that so many of them could be addressed by checking to ensure the labeling and printing on the cartons was compliant. It’s amazing that any exporter would enable their product to fail because of some basic, simple activity such as this.
One website that should be on every exporter and importer website bookmark list is http://www.fda.gov/seafood, as you can keep yourself informed on many of the issues and learn about how to avoid getting into difficulty.
I love the concept of the higher importance of training and that all employee records need to demonstrate the training activities. This has been a missing element for some time. However I am struggling with the issues regarding the Fish Names concept.
I have been heavily engaged in the Australian Fish Names Standard AS5300 SSA for many years and am very proud that our industry drove this issue to get the Standard approved in 2007 (http://seafoodstandards.com.au/fish-names/Pages/default.aspx ). In my opinion this is something that needs to be a keystone for global seafood. When I read the FDA’s Seafood List (http://www.accessdata.fda.gov/scripts/fdcc/?set=seafoodlist ) there is massive confusion about the Acceptable Marketing Name and the Common Name and then when you visit NOAA’s information you get more names – see http://www.fishwatch.gov/ .
If you do not have a one name=one fish policy, then it makes a mockery of your food safety plan specifically because of traceability and the absolute need for a food recall protocol.
No doubt we will revisit this issue at a later date.