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Farm and food groups express concerns about traceability in food safety bill

By Agri-Pulse staff

© Copyright Agri-Pulse Communications, Inc.

Washington, April 15. New traceability and recordkeeping provisions under consideration in proposed food safety legislation could be “impractical” and “unachievable,” and add a costly burden to our food production system, according to a coalition of farm and food organizations. In a letter sent April 14 to Senate Health, Education, Labor and Pension Committee Chairman Tom Harkin (D-IA) and Ranking Member Mike Enzi (R-WY), 23 organizations said that, while they have not seen final bill language, they wanted to highlight two major concerns that may be under consideration for inclusion in the food safety bill, S. 510.

Specifically, they oppose any traceability or recordkeeping provisions that would prohibit or restrict the traditional receiving, storage, handling and shipping of agricultural commodities or food/feed ingredients on a commingled basis or that subjects farms and other facilities not registered under the Bioterrorism Preparedness Act to new recordkeeping requirements.

“This commingled commodity system is integral to the efficiency and cost competitiveness of the U.S. agricultural and food system,” the groups wrote.

Currently, under a commingled commodity system, further processors are able, as required under the recordkeeping requirements of the Bioterrorism Act of 2002, to provide information on the multiple suppliers whose deliveries may comprise a processed food or feed ingredient product,

narrowing potential sources based on the timeframes of receipt and distribution.

“But expanding such recordkeeping to require processors to be able to link specific

products processed from commingled commodities to the precise individual warehouse or

farm from which the raw ingredient originated would be impractical and unachievable,

and would not yield demonstrable improvements to food or feed safety. In essence, such

a requirement would require the industry, including small entities, to begin receiving,

storing and shipping commodities on a segregated, identity-preserved basis, requiring

construction of extensive new storage facilities and use of segregated rail, truck and barge

transportation, depressing farm prices and totally undermining the ability of U.S.

agriculture to provide an abundant, affordable and safe food and feed supply.

“Second, it is imperative that any new traceability requirements initiated under S. 510 not

subject farms and other non-registered facilities to new recordkeeping requirements. The

Bioterrorism Preparedness Act already requires buyers of grains and similarly handled

commodities, as well as other food/feed intended for U.S. distribution (e.g., initial

warehouse operators) to maintain records of those from whom they purchase such

products.

“Further, we understand that the traceability language being considered also

would require restaurants and grocery stores to maintain records documenting direct

deliveries from farms. Accordingly, new recordkeeping requirements on farms and other

unregistered facilities would be redundant, as well as burdensome, particularly for small

producers. We oppose such requirements.”

The full text of the letter follows:

April 14, 2010

The Honorable Tom Harkin

Chairman

Health, Education, Labor and Pensions Committee

United States Senate

The Honorable Michael Enzi

Ranking Member

Health, Education, Labor and Pensions Committee

U.S. Senate

Dear Chairman Harkin and Ranking Member Enzi:

We appreciate your efforts and those of your staffs and other Senators and their staffs to

fashion bipartisan legislation (S. 510) that takes a science- and risk-based approach to

food and feed safety. In the months since markup of the bill by the Senate Health,

Education, Labor and Pensions Committee, many of the undersigned national agricultural

and agribusiness and food-related associations have worked with your staffs to suggest

refinements that we believe would further improve the bill.

While we await word on the extent to which our suggested improvements have been

incorporated, and because we have not seen final bill language, we want to bring to your

attention two major concerns as you examine traceability language that may be under

consideration for inclusion in S. 510. Specifically, we oppose any traceability or

recordkeeping provisions that would prohibit or restrict the traditional receiving, storage,

handling and shipping of agricultural commodities or food/feed ingredients on a

commingled basis or that subjects farms and other facilities not registered under the

Bioterrorism Preparedness Act to new recordkeeping requirements.

Regarding our first concern, it is imperative that any product-tracing or recordkeeping

requirements imposed for grains, oilseeds and similarly handled raw agricultural

commodities not be construed in a way that would restrict or prohibit the traditional

receiving, storage, handling and shipping of such commodities on a commingled basis.

This commingled commodity system is integral to the efficiency and cost competitiveness of the U.S. agricultural and food system. Under a commingled commodity system, further processors are able, as required under the recordkeeping requirements of the Bioterrorism Act of 2002, to provide information on the multiple suppliers whose deliveries may comprise a processed food or feed ingredient product, narrowing potential sources based on the timeframes of receipt and distribution.

But expanding such recordkeeping to require processors to be able to link specific