Contributing Lawyers


Cyndee Todgham Cherniak

United States

Susan Kohn Ross


Andrew Hudson

What Will Implementation of the FDA Food Safety Modernization Act Look Like?

While it is still early in the process, and the FDA already has competing demands on its limited staff, including a plethora of reports that must be submitted to Congress over the next couple of years, some signs are starting to emerge as to how the agency may implement the new Food Safety Modernization Act.

The FDA’s priorities are stated to be:

1) Prevention – mandatory controls, product safety, and intentional contamination;

2) Inspection, compliance, and response – administrative detention, recall, and suspension of registrations;

3) Import safety – foreign supplier verification, third-party certification, and mandatory certification of high-risk foods; and

4) Enhanced partnerships – with other governments, other government entities, and the private sector.

To the extent there is public health exposure, the FDA has indicated it will approach such issues on a regional basis.

To keep up to date regarding the FDA’s efforts in this area, be sure to check and for more details.

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