Clay Detlefsen, National Milk Producers Federation
As I work with food companies, I hear about a lot of things driving them crazy; everything from supplier issues, regulatory compliance, and overzealous or untrained inspectors. With the emergence of new FSMA rules and a bioengineering labeling rule in the works, the industry is going to have even more headaches. Environmental monitoring, the threat of intentional contamination of the food supply, and yet another labeling change are emerging and could be another reason for food manufacturers to reach for Tylenol.
Testing Your Way To Safe Food
I still remember the Peanut Corporation of America (PCA) fiasco from 2008 that dragged on far too long. Back then, one of the questions I kept hearing from food manufacturers was, “Can I rely on finished-product testing to show products are safe, despite the fact used we PCA products in our finished products?” Of course, the answer was a resounding “no.” You can never establish that a product is safe with finished-product testing unless you test 100 percent of the product, and in that case, there is no longer a product to sell. The reason is that the potential contamination is frequently not homogeneous, or is otherwise sporadic, and could easily be missed. Thankfully, this is a now widely-understood concept, though there are pockets here and there still thinking otherwise.
Given that, it seems odd that the FDA appeared to be considering mandatory finished-product pathogen testing when they were promulgating the Preventive Controls for Human Food Rule. Thankfully, in the end, the FDA did not impose such a requirement because the agency realized that while finished product testing is appropriate in some circumstances, robust environmental monitoring is much more effective in establishing and maintaining food safety.