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FSMA GMP Preventative Controls Comments


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#1 williamw

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Posted 28 March 2013 - 06:23 PM

Am I am working with a couple of industry grous on preparing a set of comments for the proposed rules but I am finding that in some cases it is hard to be to some of the "nitty gritty" issues. It occurred to me that it might be good to offer a comments that represent the views of food safety professionals that are working with these issues daily and might like to have a chance to put in their comments without necessarily having them tied to an industry association or their company. The idea would be to establish an ad hoc committee of food safety professionals and to submit comments from that group without tying them to the individuals or companies. We would establish some credentials by including some type of collective description of the size and experience of the group.
I do not think we could tie this to ifsqn so if there is interest I think we should take the discussion and development of comments to another place on the web. There are plenty of places to establish a free forum and other tools that would allow us to develop a set of comments. Of course we would also have to establish some agreed to mechanisms to determine which comments the group supports etc, but that would come once we have a group formed.
At this point I just want to know if others are interested. If I get 15 to 20 people that are I will set up some way for us to communicate as a group and work on comments together. At that point we should share enough information about ourselves to establish credentials and expertise, but not necessary anything that would identify us personally.



#2 Simon

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Posted 28 March 2013 - 07:58 PM

Why can't it be done from here William? And why can't it be open discussion?
The IFSQN is respected worldwide and our members are very much grass roots and extremely knowledgeable.

If it cannot be open discussion then there is the facility to set up private special interest forums here.

Regards,
Simon


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#3 williamw

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Posted 28 March 2013 - 09:30 PM

Well I guess I made an unfounded assumption that we would not be able to do it under the IFSQN name, if that is acceptable I think that would be a good way to identify where the comments are coming from just as a trade association would identify themselves. I see no problem using an open forum to develop the comments and since the rules will have implications both for US based facilities and foreign facilities that import into the US the international perspective this forum offers would be good.






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