Those comments also expressed concern with the direction of FDA’s proposal, and asked the agency to “fundamentally reconsider its proposed approach.” Like dairy farms, dairy processing facilities have worked with FDA to take an active approach in applying food defense concepts to their manufacturing operations, according to the two organizations.
IDFA and NMPF proposed that FDA only require basic food defense plans consisting of cost-effective mitigation strategies, allowing facilities to then identify reserved focused mitigation strategies that can be quickly implemented in response to heightened concerns or credible threats, should they be deemed necessary.
The joint comments also emphasized that each processing facility and dairy farm is unique. If FDA were to require food defense plans, the dairy industry must have the flexibility to address intentional adulteration in ways that are custom-tailored with respect to their individual attributes, rather than prescribing “one-size-fits-all” specific criteria.
The National Milk Producers Federation, based in Arlington, VA, develops and carries out policies that advance the well-being of dairy producers and the cooperatives they own. The members of NMPF’s cooperatives produce the majority of the U.S. milk supply, making NMPF the voice of more than 32,000 dairy producers on Capitol Hill and with government agencies. Visit www.nmpf.org for more information.