Good morning, everybody. Thank you for inviting me to speak with you. I find it an honour to speak with the Canadian government, so I appreciate your time.
My name is Scott Zimmerman. I own a company here called Safe Quality Seafood Associates. We're a consultancy. I'm basically an external quality assurance and quality control person. I work for the industry, I work for FDA and I address compliance issues specific to the seafood industry.
Today I'm going to speak briefly with you folks about FDA regulations, NOAA regulations and third party requirements for traceability in the United States.
The first topic I want to touch on is a new proposed rule by the FDA that covers requirements for additional traceability outside of the “one-up, one-down” required through the bioterrorism act. This new regulation is under the new U.S. Food Safety Modernization Act, which came about in 2011 and is still being implemented. The goal of the new traceability requirements is to reduce the time needed, during an outbreak especially, to identify contaminated product. That will address one of four different core elements in FDA's new smarter era for food safety.
Going beyond one step forward and one step backward, any food that has been listed on the food traceability list, which in the case of seafood is just about every type of seafood, will require key data elements, such as temperature and traceability codes, that are collected during critical tracking events. That is especially when product is moving from one hand to another in the chain of custody. This is increasingly needed for especially ready-to-eat foods that don't have a “kill step” before the consumer opens the package and eats it.
The critical tracking events that FDA will focus on include the growing, which would include aquaculture operations, or the receiving, which would include taking raw material off a fishing vessel. The production of the food would require traceability as a critical tracking event. Different types of key data elements, such as temperature, for example, would be required to be collected at that step. Any step where raw material product is transformed would require traceability data, including shipping. FDA is going to expect all of that traceability to be collected in a sortable spreadsheet, such as an Excel spreadsheet, in order to be considered compliant.
The next traceability program I want to talk about is the National Oceanic and Atmospheric Administration's seafood import monitoring program. This is a program that's relatively new. It's required under the Magnuson-Stevens Fishery Conservation and Management Act here in the U.S. to combat illegal, unreported and unregulated fisheries or misrepresented seafood from entering the United States and entering commerce.
NOAA officers are required to conduct these audits of importers here in the U.S. and make sure that there's critical information collected at each point of movement, or the chain of custody. Currently this seafood import monitoring program is restricted to 13 imported fish and fish species groups, which means, if you look at it from a greater perspective, 1,100 unique species of fish are being traced by NOAA at this time. But there are lobbying efforts taking place here in the United States to include additional species to the seafood import monitoring program, or SIMP.
SIMP and NOAA have recognized that there are groups of importers in the United States who have maintained compliant programs. They've created a compliant importers list as a function of that. That's going to recognize those importers here in the U.S. that have demonstrated a history of compliance.
The last traceability component I'd like to talk about is not regulatory. It's voluntary. That's through third party certification. There are several different standard owners, such as the MSC, the ASC or Aquaculture Stewardship Council; the BAP or Best Aquaculture Practices; the BRC, which is the British Retail Consortium; and SQF or Safe Quality Food, just to name a few.