While complimenting USDA for trying to create a regulatory system to implement a “flawed law” in the most reasonable way, FMI asked that recordkeeping requirements be amended to allow a complete record applied to an individual package or to a carton of bulk product by the supplier with knowledge to serve as the only record necessary at retail.
USDA should drop the requirement that the information be captured by intermediary suppliers along the supply chain. Also, the specific parties required to maintain records should only have to do so until the product is sold at retail. FMI asked USDA to establish a new effective date for the final rule and urged it to consider applying the Food Safety and Inspection Service uniform compliance date policy.
