This week the US Food and Drug Administration (FDA) announced a proposed rule to establish additional traceability recordkeeping requirements for certain foods that are considered "high-risk" sources of foodborne illness outbreaks, a list that includes seafood.

The FDA's list includes all finfish species, such as cod, haddock, Alaska pollock, tuna, mahi mahi, mackerel, grouper, salmon and other. It does not include siluriformes fish, however, such as catfish.

"This year, as the FDA moves towards an evolution in traceability, NFI’s members have proactively explored technologically enabled traceability through a blockchain pilot to test its viability in a real seafood value chain," said John Connelly, president of National Fisheries Institute (NFI) of the proposed rule.

But the NFI is currently reviewing the rule, and is questioning its necessity.

"And as with any new regulatory structure, we are interested in ensuring there are no duplicative systems that would complicate the new traceability parameters," he said.

Connelly added the approach to including seafood in a large list of other foods suggests the FDA is taking a "one size fits all approach," which he added, "may not be warranted."

Last year the FDA unveiled what it described as a "new strategy" to better enforce the safety of food imported into the United States. As part of that strategy, the FDA called out the fact that 94 percent of the seafood Americans consume is imported as part of the agency's rational for developing its Food Safety Modernization Act (FSMA).

Imported seafood has traditionally been exempted from FDA programs because there has been a substantially similar system in place for decades for fish and shellfish production through the FDA's Hazard Analysis and Critical Control Point (HACCP). The FDA also already has a guide to those exemptions and how to understand where seafood fits into its Food Safety Modernization Act (FSMA).

Key Data elements (KDE) and Critical Tracking Events (CTE) are already being collected by importers who must comply with NOAA’s Seafood Import Monitoring Program (SIMP), Scott Zimmerman, CEO of Safe Quality Seafood Associates (SQSA), a consultancy focusing on seafood safety, told IntraFish.

Zimmerman added, however, SIMP is also only required for a select group of species, and the FDA’s new proposed requirements are for a much broader group of products.