Prepared Foods Exclusive: Regulatory Environment in 2010
With so many issues before congress and the executive branch, the 2010 crystal ball looks a little foggy. While matters such as war, health care, and the economy will occupy much attention, certain non-final matters begun in 2009 will carry over. In addition, there are matters with compliance dates in 2009 but for which companies should check for full compliance heading into 2010, and there is always the risk that the next crisis or attention-grabbing headline will usher in a legislative or regualtory mandate.
Food companies should have in place procedures to implement the requirements of the Reportable Food Registry. "Responsible parties," including those facilities registered with FDA, are engaged in the manufacture, processing, and holding of food for consumption in the United States. When a responsible party becomes aware of a reportable incident (generally equivalent to the criteria of a Class 1 recall), it must use the "electronic portal" to alert FDA within twenty-four (24) hours of becoming aware that the food constituted a reportable incident.