In FDA’s RFR Report, Some Intriguing Numbers

By Ricardo Carvajal -

FDA released a report summarizing the first seven months of the agency’s experience with its Reportable Food Registry (for more on recent developments pertaining to the RFR, see our prior posting here). The data summarized by FDA show how the potential adulteration of a widely used ingredient such as hydrolyzed vegetable protein ("HVP") can trigger a deluge of RFR reports. In March alone, FDA received 1001 reports related to the potential presence of Salmonella in foods containing HVP. This accounts for almost half of all submissions received by the agency during the entire reporting period. The data also confirm that less than 10% of submissions are what the agency refers to as “primary reports,” meaning “the initial report concerning a reportable food from either industry or public health officials, such as federal, state, or local regulators.” The vast majority of submissions are so-called “subsequent reports,” meaning “a report submitted by either a supplier (upstream) or a recipient (downstream) of a food/feed (including ingredients) for which a primary report has been submitted.” Put these facts together and it appears that the RFR is generating lots of data about the chain of distribution of potentially adulterated products. Small wonder that the Deputy Commissioner for Foods is singing the RFR’s praise.

The agency cautions that “it is too early to draw inferences concerning patterns of food and feed adulteration." However, we can't resist the observation that the vast majority of the primary reports were precipitated by foodborne pathogens and undeclared allergens/intolerances – a pattern similar to what we have observed in Class I recalls.