FDA Issues Final Rule on the Establishment and Maintenance of Records and Draft Guidance Regarding Records Access

From: Pamela Tom (pdtom@ucdavis.edu)
Date: Tue Dec 07 2004 - 12:40:48 PST

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    On December 6, 2004 the U.S. FDA issued final regulations on the
    establishment and maintenance of records to protect the U.S. human food
    and animal feed supply in the event of credible threats of serious adverse
    health consequences or death to humans or animals.
    http://www.fda.gov/OHRMS/DOCKETS/98fr/02n-0277-nfr0001.pdf (344 pages)

    FDA also issued draft guidance to FDA staff and industry, which details
    the internal procedures the agency will follow before requesting access to
    records.
    http://www.cfsan.fda.gov/~dms/secgui12.html

    This is the fourth and final regulation designed to increase the safety
    and security of the U.S. human and animal food supply under the authority
    of the "Public Health Security and Bioterrorism Preparedness and Response
    Act of 2002" (the Bioterrorism Act).

    The record retention period for human foods ranges from six months to two
    years depending on the shelf life of the food. Records for animal food,
    including pet food, must be retained for one year. The maximum record
    retention requirement for transporters of all types of food is one year.

    Records must be retained at the establishment where the activities covered
    in the records occurred or at a reasonable accessible location. To
    minimize the burden on food companies affected by the final rule,
    companies may keep the required information in any format, paper or
    electronic. All businesses covered by this rule must comply within 12
    months from the date the rule is published in the Federal Register, except
    small and very small businesses. Small businesses (11-499 full-time
    equivalent employees (FTEs)) must comply within 18 months from this date,
    and very small businesses (10 or fewer FTEs) have to comply within 24
    months from this date.

    When FDA has a reasonable belief that an article of food is adulterated
    and presents a threat of serious adverse health consequences or death to
    humans or animals, any records or other information to which FDA has
    access must be available for inspection and copying as soon as possible,
    not to exceed 24 hours from time of receipt of the official request. The
    records access authority applies both to records required to be
    established and maintained by the final rule, or any other records a
    covered entity may keep to comply with federal, state, or local law or as
    a matter of business practice.

    FDA has already issued three other final regulations under the
    Bioterrorism Act, which are in effect. They cover:

    - Registration foreign and domestic food facilities;

    - Prior notice of food shipments imported or offered for import into the
    U.S.; and

    -Administrative detention, so that food products that might pose a threat
    of serious adverse health consequences or death may be detained.

    FDA will be holding seven public meetings across the U.S. in January and
    February 2005 to explain the requirements of the final rule to interested
    parties and answer questions.
    http://www.cfsan.fda.gov/~dms/fsbtac24.html

    A fact sheet on FDA's New Food Terrorism Regulation: Establishment and
    Maintenance of Records is available on line at:
    http://www.cfsan.fda.gov/~dms/fsbtac23.html

    Source: FDA News, December 6, 2004
    http://www.fda.gov/bbs/topics/news/2004/NEW01143.html

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