The Development of a Comprehensive Food Recall System

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FDA Recall Cooperative Agreement (U18) RFA-FD-12-026 Proposal Abstract The Washington State Department of Agriculture (WSDA) seeks funding from the U.S. Food and Drug Administration (FDA) under RFA-12-026. The funding level requested is for $300,000 for a three year period. The title of our proposal is: "The Development of a Comprehensive Food Recall System." If awarded, WSDA will hire a full-time project Recall Coordinator to enhance and expand the agency's efforts in protecting public health. Currently WSDA handles recalls in response to human illness reports that are associated with a product, or in response to pathogen findings in food or feed products. With each recall, one or more of our existing managers shift from their regular duties to handle the interface with the affected processor/distributor, in order to aid them with their information collection, their Reportable Food or Feed Registration (RFR) responsibilities, and other details that go into an effective recall. In effect, our managers take on the role of a recall coordinator. Whenever a manager is pulled away from their day-to-day activities other important work is delayed or goes undone. In addition, many times WSDA has needed to request the FDA Seattle District office to assist firms with recalls, even if there is no interstate commerce of product. In addition, WSDA's limited strategy on allergens has been to issue compliance warning letters to firms that fail to meet allergen requirements. Those warning letters are then provided to FDA who may initiate their own inspection, resulting in recalls due to continued non-compliance concerns. Thru this award WSDA could develop an active allergen recall thereby further protecting public health. WSDA has long worked with other state agencies to improve our effectiveness on recalls. One important example of this is our sustained effort over the past two years to improve food processor, local health jurisdiction, and academic knowledge on how food recalls are accomplished in the state of Washington. Food processors and warehouse operators who have a better understanding of how effective recalls are undertaken are more likely to reduce everyone's workload, if and when they need to conduct a food recall. This knowledge also helps to make the recalls more efficient and effective. In September 2010, and early 2012, WSDA teamed up with the FDA Seattle District Office, the Washington State Department of Health, Washington State University's Food Science Program, and leading Washington food industry businesses to present five workshops focused solely on the "hows and whys" of food safety recalls. This training was so well received, with over 175 attendees participating, WSDA plans to repeat the workshop in 2013. The eight hour food recall workshops completed to date were accomplished with funding from two FDA Food Protection Conference grants, many volunteer hours, and teamwork between WSDA and key players involved in food recalls across our state. While our efforts to get the word out on the need to be prepared for food safety recalls is important, our agency must improve its own ability to handle all aspects of these recalls with the same level of expertise and thoroughness we seek from the industry we regulate. A new full-time Recall Coordinator will eliminate the ad hoc basis we now use to handle recalls. If we receive this award, we plan on focusing our effort on implementing Standards 3, 5, 6 and 7 of the Manufactured Food Regulatory Program Standards (MFRPS) as they pertain to allergen inspections, recalls, compliance and industry outreach. In particular, we will improve our recordkeeping and complete a much more thorough follow through on food recalls. We will also initiate a new and aggressive response and compliance strategy to WSDA inspectional findings of undeclared allergens, particularly in our food processors with intrastate only product distribution. This will dramatically improve our recall effectiveness and protect public health.