(Part 1 of a multi-post series)
Participate in the FDA direction on food e-commerce. This is a review of the Federal Register announcement earlier today about the FDA food safety/e-commerce public meeting on October 19, 2021. The event addresses e-commerce and new business models based on supply chain innovations such as food delivery.
Link to the Federal Register Notice publication that announced the FDA “New Era in Smarter Food Safety Summit on E-Commerce”: https://www.federalregister.gov/documents/2021/09/07/2021-19219/food-and-drug-administration-new-era-of-smarter-food-safety-summit-on-e-commerce-public-meeting
[This is the first blog post in our multi-post series that focuses on the FDA “New Era of Smarter Food Safety” (SFS) blueprint. Other posts will include an e-commerce overview, e-commerce and cybersecurity definitions, a country-level vulnerability assessment, an explanation of supply chain mapping and the use of criminology hot spot analysis, and possibly others.]
FDA’s New Era in Smarter Food Safety (SFS) – the Foundation
From FDA: “The New Era of Smarter Food Safety represents a new approach to food safety, leveraging technology and other tools to create a safer and more digital, traceable food system. Smarter food safety is about more than just technology. It’s also about simpler, more effective, and modern approaches and processes. It’s about leadership, creativity, and culture. This blueprint outlines the approach FDA will take over the next decade to usher in the New Era of Smarter Food Safety. It will evolve as food technologies and the food system evolve. It builds on work that FDA has done to implement the FDA Food Safety Modernization Act (FSMA), which established science and risk-based protections.”
FDA’s SFS Meeting on E-Commerce
Generally, this is an information-gathering meeting to review all aspects of “Ensuring the Safety of Foods Ordered Online and Delivered Directly to Consumers.” For this meeting the definition and scope of the e-commerce term is:
- E-commerce/ B2C e-commerce: is the manufacturing, packaging, labeling, storage, and delivery of human and animal foods sold directly to consumers through commercial transactions conducted electronically on the internet. (Note: B2C is “business-to-consumer,” which is different from B2B “business-to-business” or C2C “consumer-to-consumer.”)
The ”new business models” include:
- Types of Businesses: “Types of B2C e-commerce models (e.g., produce and meal kit subscription services, ghost kitchens, dark stores),” A later statement added: “Partner with food delivery companies to provide education on the importance of proper food handling, including outreach to delivery services such as the U.S. Postal Service, UPS, FedEx, Uber, Lyft, DoorDash, etc.”
- Types of Delivery: “Types of delivery models (e.g., third-party delivery, autonomous delivery models);”
- Gaps in Current Regulations: “Regulatory approaches to food sold through B2C e-commerce, including challenges and gaps that need to be addressed.” A later statement added: “Work with regulatory partners to address new business models that FSMA may not currently cover (e.g., address who “owns” the food in the last mile).”
Key Concepts
The FDA is taking a proactive first step aligned with standards such as ISO 31000 Risk Management of “establishing the context.” Following ISO 9000 Quality Management and ISO 22000 Food Safety Management, the next step is to gather incident information to conduct risk identification before considering the risk assessment models or methods. Key steps include supply chain mapping to identify how product flows and who handles the products. This provides the information to conduct a criminology hot spot analysis outlined in the USDA Organic Integrity Learning Center video training courses on food fraud prevention.
Call to Action
If you have followed our Food Fraud Prevention research and training, these methods and processes should be familiar. Now, take the opportunity to be a part of developing the US food supply chain’s e-commerce food safety system. Complete the free registration for the October 19, 2021, FDA public meeting through this link.