Protecting Susceptible Populations from Chemical Contaminants in Food

By: Suzanne Fitzpatrick, Ph.D., DABT

Anyone who regularly eats food containing low levels of certain chemical contaminants may be adversely affected over time. But some groups of people are more sensitive to chemical contaminants than others and thus are more likely to be harmed by long-term exposure. We call these groups “susceptible populations.”

Suzanne FitzpatrickThe FDA’s charge to ensure the safety of the food supply is not limited to the protection of the general public. We also have a responsibility to protect susceptible populations.

Pregnant women, infants, young children, and older adults have long been recognized as susceptible populations by the scientific community. In addition, people with cancer, diabetes, HIV/AIDS and transplant recipients may have weakened immune systems and thus may also be more vulnerable. In short, these groups may be at greater risk from a given amount of a chemical contaminant because of their age, genetics, sex, or health status.

Committed to protect susceptible populations as best we can, the FDA convened its Food Advisory Committee on December 16-17, 2014 to help shape our efforts to understand when and how risk assessments should integrate concern for susceptible populations.

Conducted and used by regulators, risk assessments are one of the most objective and scientific ways to understand the potential adverse health effects of chemical contaminants in the food we eat. They help regulators apply science in policy and decision-making. Think of them as a foundation for risk management, a bridge between data and decisions.

At times, however, susceptible populations may require special consideration. They may even warrant separate risk assessments under certain circumstances. If we evaluate their risk with the same broad brush that we apply to the general population, we might miss certain realities. In pregnant women, for example, metals like cadmium, lead and arsenic can cross the placenta and may harm the fetus while its neurological and immune systems are in their earliest stages of development. Similarly, senior citizens may have nutritional deficiencies or cardiovascular problems that make them more susceptible to certain contaminants.

We asked difficult questions of the Food Advisory Committee. To paraphrase a few, we asked what factors the FDA should use to define a susceptible population, what data and level of confidence are needed to initiate a separate assessment for any given susceptible population, and whether there are subpopulations or life stages of particular concern. We also asked several technical questions.

My colleagues and I hope to make meaningful inroads toward better understanding the risks faced by susceptible populations through our risk assessments, in part with the committee’s help. We are confident that we are on the right track. In fact, our effort aligns with a recent report by the National Academy of Sciences (on inorganic arsenic), which suggests that, depending on the chemical, separate risk assessments may be warranted for certain susceptible populations.

We will study the committee’s advice to consider how we can best incorporate susceptible populations into our risk assessments. Ultimately, we know that it might not always make sense to take a “one-size-fits-all” approach when it comes to food safety.

Suzanne Fitzpatrick, Ph.D., DABT, is the Senior Advisor for Toxicology in FDA’s Center for Food Safety and Applied Nutrition.

Another important step in FDA’s journey towards enhanced safety through full-scale “active surveillance”

By: Janet Woodcock, M.D.

They say the longest journey begins with a single step. In 2008, FDA launched the Sentinel Initiative and thus began a long journey toward the challenging goal of developing a full-scale medical product safety monitoring program using an important scientific technique called “active surveillance,” which complements our FDA Adverse Event Reporting System (FAERS). FAERS is already well developed and uses the equally important technique of “passive surveillance.” Today, I’d like to recognize our progress along the way.

Janet WoodcockAfter a successful five-year pilot program, which began in 2009, FDA’s Mini-Sentinel program is now transitioning, as planned, to the full-scale Sentinel System. I’d like to share with you the success of our Mini-Sentinel pilot program and some of FDA’s visions for our new leg of the journey toward full-scale “active surveillance” under the new Sentinel System.

First, a quick discussion of the importance of “active surveillance”: Over many years, FDA’s program that we now call FAERS has been our main tool for assessing the safety of medical products. This system relies on patients, medical professionals, and product manufacturers to report to us potential safety issues of the products FDA regulates.

FAERS is an invaluable asset, and we’re not seeking to replace it. However, the Sentinel System offers us the exciting possibility of not waiting for safety information to come to us in the form of reports, but rather it enables us to go out and get that information, adding greatly to our safety monitoring capability. This is active surveillance.

Over the past five years, the Mini-Sentinel pilot program has established secure access to the electronic healthcare data of more than 178 million patients across the country, enabling researchers to evaluate a great deal of valuable safety information. While protecting the identity of individual patients we can get valuable information from Mini-Sentinel that helps us better understand potential safety issues, and share with you information on how to use medicines safely. We have used Mini-Sentinel to explore many safety issues, helping FDA enhance our safety surveillance capabilities, and giving us valuable input in decision-making on drugs and vaccines.

We’re now well on our way to developing a nationwide rapid-response electronic active surveillance system, Sentinel System, for monitoring the safety of FDA-regulated drugs and other medical products.

So where does our journey take us from here?

  • FDA will build on the successes of the Mini-Sentinel Pilot. We have a variety of safety assessments ongoing under Mini-Sentinel that will continue and we will seek to expand our reach and capabilities with the Sentinel System;
  • Mini-Sentinel gave us an important start, but it is essential to continue to develop and refine existing scientific methods to evaluate the data we access through the Sentinel System;
  • We see Sentinel as a potentially valuable national resource for other safety researchers, besides those at FDA. Looking even further ahead, our hope is that, working with other scientific groups, we will be able to create a National Data Infrastructure that would enable other users (e.g., other governmental agencies, researchers from academia or industry) to access the Sentinel infrastructure for multiple purposes (e.g., medical product research, quality improvement);
  • Not only will such access directly serve the public health, it will also help sustain these programs because stakeholders will have an incentive to provide support (financial and otherwise) for its maintenance and growth.

From the outset, the goals of the Sentinel Initiative have been large and of ground-breaking scale. We knew it would be years in the making, but Mini-Sentinel’s successful completion marks important progress. We look forward to continuing and expanding our active surveillance capabilities as we now transition to the full-scale Sentinel program.

Janet Woodcock, M.D., is the Director of FDA’s Center for Drug Evaluation and Research

Food Safety Together

By: Mary Lou Valdez and Julie Moss Ph.D., R.D.

In early December, we represented the FDA in Cape Town, South Africa, at the third annual conference of the Global Food Safety Partnership (GFSP). FDA has been a strong supporter of the GFSP since 2012, when it was launched by the World Bank and Commissioner Margaret A. Hamburg, M.D., gave the keynote address at the first conference. FDA provides the Partnership with financial support and technical expertise.

Julie Moss (left) and Mary Lou Valdez (right)

Julie Moss (left) and Mary Lou Valdez (right)

The World Bank is uniquely positioned to facilitate the GFSP and create a “big tent” where all parties in the global supply chain can work together to help ensure that all food products are safe for consumers. While government agencies like FDA develop standards and regulations, and provide regulatory oversight, it is the food industry, not the government, which produces safe food for consumers. To be successful in improving global food safety, we need to create partnerships across nations and sectors. The unique role of GFSP is to enable and catalyze a clear strategic direction to strengthen food safety systems and supply chains globally in ways that can only be achieved or enhanced collectively.  The GFSP brings together government, industry, academic, consumer and international organizations, providing a unique and valuable opportunity for all of these parties to cooperate in new and creative ways to improve food safety. This requires coordination to focus our efforts and avoid duplicating each other’s work.

Attendees at the 2014 Food Safety Global Conference.

Attendees at the 2014 Food Safety Global Conference.

During the conference, we acknowledged progress on many ongoing food safety activities (e.g., needs assessment progress in Zambia and Good Aquaculture Practices training in Malaysia, among others) and we moved forward in building a framework for a long-term strategy to collectively support and sustain investment in food safety systems. Yet, there is still much work ahead for 2015, which will be a critical year for the GFSP, as we will further refine our strategy and look forward to making great strides in key GFSP initiatives, including work to strengthen food safety systems in China and Zambia. Success in protecting the safety of the world’s food requires a new paradigm with new partnerships across nations and sectors. Moving forward, we intend to work to expand and promote this valuable partnership in the coming year to continue to strengthen the global food safety net for all consumers.

At FDA, we recognize that today’s food supply chain is global, complex, and interconnected. Because the U.S. imports half of its fresh fruits and 80 percent of its seafood, our efforts to protect the U.S. food supply must be global, and we must build strong partnerships to create a world-wide product safety net to protect public health. GFSP is an example of our ongoing efforts to build partnerships as we aim to prevent unsafe products from entering the market, no matter where the products come from or where they are consumed.

Mary Lou Valdez is FDA’s Associate Commissioner for International Programs

Julie Moss, Ph.D., R.D., is Deputy Director, International Affairs Staff in FDA’s Center for Food Safety and Applied Nutrition

Together: A Food Safe America

By: Michael R. Taylor

I recently had the pleasure of speaking at the Consumer Food Safety Education Conference convened by the Partnership for Food Safety Education (PFSE). The conference brought together food safety educators from across the country – people in state and local health departments, universities, extension services, and food businesses who are working every day on the front line, with consumers, to reduce food safety risks by improving consumer food handling practices.

Michael Taylor

Michael Taylor

The theme of the conference was “Together: A Food Safe America” – a theme that captures so well the sense of community, high purpose and energy that were present so abundantly at the conference. I shared the podium with two good friends and colleagues representing key FDA partners on food safety – USDA’s Acting Under Secretary for Food Safety Brian Ronholm, and Joe Corby, the Executive Director of the Association of Food and Drug Officials, which represents state and local food safety officials.

We regulators have a responsibility, through our oversight of the food industry, to do everything we reasonably can to make sure that the foods consumers bring into their homes are as safe as they can be. We are doing this by building into our food safety standards and compliance programs modern concepts and techniques for preventing the contamination that can make people sick.

Under the FDA Food Safety Modernization Act (FSMA), we at FDA have a new mandate to build a farm-to-table system of prevention, encompassing work that must be done to make food safe at four major stages of the commercial food system. These pillars of prevention include:

  • Production of produce on the farm,
  • Practices in food processing and storage facilities,
  • Transportation of food, and
  • Practices in grocery stores and restaurants.

But there’s a fifth pillar of prevention, and that’s the consumer. We all know that, even with the best of efforts by commercial food producers and handlers, consumers still must play a crucial role in preventing the introduction and spread of contamination – by keeping their hands and food surfaces clean, by keeping raw meat and produce separate, and by being sure to cook food to proper temperatures and chill food through prompt refrigeration.

It seems like common sense – and the basic ideas are – but food safety educators know that it’s far from simple to provide consumers the information, tools, and motivation they need to turn common sense into sustained behavior change. But they are out there, every day, doing the hard work.

We in government and the food industry need to better support our food safety educators.  FDA, USDA, and the Centers for Disease Control and Prevention (CDC) do some good work on food safety education. For example, at FDA, our current programs include targeting groups and individuals who are especially vulnerable to foodborne illness and partnering with the National Science Teachers Association to incorporate food safety into the science curriculum at the middle and high school levels. But there is more we can do to support food safety educators at the front line, in their daily work with consumers in clinics, in schools and in communities – where most of the food safety education, and all of the behavior change, takes place.

At FDA, we will be building food safety education into our risk-based priority setting paradigm, which means documenting better the contribution that education makes to reducing risk, evaluating what works to sustainably improve consumer practices, and targeting resources where they will make a real difference. Federal food safety agencies – and their finite resources – are overwhelmingly focused on the congressional mandate to prevent hazards arising from the commercial supply chain, which makes sense: that’s what we regulate. But, backed up by the right analysis, we can effectively target and increase our investment in consumer education in ways that will make a real difference for public health.

But the federal government can only do so much. And that’s where PFSE comes in. The Partnership brings together government, industry and consumer leaders to pool their expertise, share their perspectives, and collaborate on the hard work of food safety education. I applaud and thank the consumer groups, food companies, and trade and professional associations that are contributing their time, creative energy and resources to the work of the Partnership. And I salute the PFSE’s Executive Director Shelley Feist for her leadership and her sustained commitment to food safety and consumer education.

Working hard, and working together, we can have a Food Safe America.

Michael R. Taylor is FDA’s Deputy Commissioner for Foods and Veterinary Medicine

FDA’s Janet Woodcock, M.D., recognized by the Institute for Safe Medication Practices: Receives Lifetime Achievement Award for her career in public service

By: Margaret A. Hamburg, M.D.

FDA’s mission is to protect and promote the health of the American public. The FDA employees who dedicate their careers to this worthy goal do so not for personal reward or public recognition but because of an extraordinary commitment to improving public healthcare. Which is why it is even more special when these employees receive public acclaim.

Margaret Hamburg, M.D.

Margaret A. Hamburg, M.D., Commissioner of the Food and Drug Administration

One such individual is Dr. Janet Woodcock, director of FDA’s Center for Drug Evaluation and Research (CDER). Janet recently was awarded the Institute for Safe Medication Practices (ISMP) Lifetime Achievement Award, recognizing “an individual who has had a significant career history of making ongoing contributions to patient safety and has had a major impact on safe medication practices.” This award is well deserved.

During her nearly 30 year career with FDA she has served in several different capacities in addition to her current position, including Director of the Office of Therapeutics Research and Review in the Center for Biologics Evaluation and Research (CBER) and as FDA’s deputy commissioner and chief medical officer. Throughout her career, Dr. Woodcock has helped the Agency elevate and transform its approach to medical product safety, personally leading the way on many key safety initiatives from their beginning to implementation.

During her distinguished career Dr. Woodcock:

  • Conceived and oversaw creation of the Adverse Event Reporting System (AERS) system, to manage the increasing number of spontaneous reports of adverse drug reactions submitted to FDA;
  • Co-led the FDA Task Force on Risk Management, one of the Agency’s first efforts to clearly delineate pre- and postmarket safety surveillance and management of medical product risks;
  • Chaired the Council on Pharmaceutical Quality, launched in 2007, presaging many of the Agency’s subsequent safety initiatives;
  • Led the launch of Safety First, a program created to help ensure alignment between premarket drug safety review and postmarket surveillance;
  • Led the creation of the Sentinel Initiative, a data-driven national system that allows active—close to “real time”—safety surveillance using electronic data from healthcare information holders;
Janet Woodcock

Janet Woodcock, M.D., Director of FDA’s Center for Drug Evaluation and Research

Through all of these accomplishments, and many others, Janet Woodcock has helped ensure that FDA can fulfill its mission effectively. She has championed the use of innovative new tools and approaches, and she has forged and enriched many partnerships with industry, academia, healthcare providers, patients and colleagues in government, including across the FDA.

Her work has helped lead FDA into a new century, an extraordinary time of transformation and opportunity in medical science. With these changes, FDA’s responsibilities have also grown enormously. We must continue to ensure that our capabilities for drug product evaluation, oversight, and regulation keep pace with these developments. Thanks to Janet’s vision and hard work, along with many of her colleagues at FDA, I am confident that FDA is up to the task.

I want to thank Dr. Woodcock for her years of dedicated service to the American public, and congratulate her on this most recent recognition of her many contributions.

Margaret A. Hamburg, M.D., is Commissioner of the Food and Drug Administration

Protecting the Public from Unsafe Compounded Drug Products

Margaret A. Hamburg M.D.

In 2012, a devastating outbreak of fungal meningitis linked to a contaminated compounded drug product tragically resulted in the loss of 64 lives and caused more than 751 illnesses, many of which were very serious. These events were a powerful reminder of the potential harm that could be caused by unsafe compounding products.

Margaret Hamburg, M.D.FDA is moving aggressively on many fronts to protect the public from such threats.

For example, we have conducted more than 175 inspections of compounding facilities in the past two years. Some of these inspections were for cause and were performed after we received reports of serious adverse events related to drugs made by compounding pharmacies or when states requested our assistance. Other inspections were proactive, targeted at facilities identified through a risk-based model. Our proactive inspections were conducted in coordination with state officials from around the country and focused on each firm’s sterile drug production, because drugs labeled as sterile are used in ways that could greatly compromise patient care and safety if they aren’t actually sterile.

Our findings uncovered a variety of problems with sterile drug production practices at these facilities. As a result of these inspections, numerous firms stopped making sterile drugs and many recalled drug products that had been made under substandard conditions. In some cases, we worked with state officials to revoke or suspend pharmacy licenses. We also issued warning letters to firms that were producing drugs under inadequate conditions, notifying them of violations of the law and the need to take steps to correct the violations and prevent their recurrence.

We have also worked with the Department of Justice (DOJ) to hold facilities accountable if they harm patients or engage in serious violations of federal requirements that put patient safety at risk. Working with DOJ, FDA has initiated investigations and enforcement actions against compounding facilities that violate federal law – and we intend to continue this work with DOJ.

In addition to our inspection and enforcement efforts, FDA has taken many steps to implement the compounding provisions of the Drug Quality and Security Act (DQSA) — legislation enacted by Congress last year in response to the fungal meningitis outbreak.

To implement the compounding statutory provisions, FDA is establishing a policy framework to address compounding by state-licensed pharmacies as well as the new category of outsourcing facilities, which was created under the DQSA. Among other things, outsourcing facilities are facilities that compound sterile drugs and choose to register with FDA as outsourcing facilities, and they must comply with current good manufacturing practice requirements and are subject to FDA inspection on a risk-based schedule.

Two years after the fungal meningitis outbreak our hearts continue to go out to the victims of the tragedy and their families. Our work on behalf of all patients who want and deserve medicines that do not subject them to undue risk is far from being done. FDA will continue to work with the states, the Department of Justice and others to enable Americans to have greater confidence in their compounded drugs.

Margaret A. Hamburg, M.D., is Commissioner of the Food and Drug Administration

Tragic Deaths Highlight the Dangers of Powdered Pure Caffeine

By Michael M. Landa

On Tuesday, Dec. 9, my colleagues and I met with the parents of two young men who died after using powdered pure caffeine.

Michael M. LandaLogan James Stiner, an 18-year-old high school senior, prom king and athlete just days away from graduation, died on May 27, 2014 at his Ohio home after taking powdered pure caffeine. On June 24, 24-year-old James Wade Sweatt of Georgia, newly married and a recent graduate of the University of Alabama at Birmingham, died after being in a coma caused by his use of powdered pure caffeine.

Their parents spoke with us about how both young men were healthy, intelligent, and careful about what they put in their bodies.

They learned, and shared with us, that Logan and Wade both thought this form of caffeine would be a safe way to get an energy boost. Both were able to obtain it cheaply and easily. Wade had sought out the product as a way to avoid the added sugar and sodium associated with soda or energy drinks. He had even downloaded a conversion chart to try to calculate the right dose to take.

Katie and Dennis Stiner, and Julie and James Sweatt, came to the FDA in hopes of sparing other families this terrible loss.

We share that goal. That’s why, after learning of Logan’s death, the FDA posted a consumer advisory warning of the dangers of consuming powdered pure caffeine.  Symptoms of caffeine overdose include rapid or erratic heartbeat and seizures.

We are working right now on our next steps. In the meantime, I cannot say strongly enough how important it is to avoid using powdered pure caffeine. The people most drawn to it are our children, teenagers, and young adults, especially students who want to work longer to study, athletes who want to improve their performance, and others who want to lose weight.

The powdered pure caffeine that the Stiners and Sweatts brought to show us—readily available for purchase online—was packaged in the same way as protein powder and marketed as a source of energy, rather than a stimulant. The reality is that these products are 100 percent caffeine, with a single teaspoon roughly the equivalent to the amount in 25 cups of coffee. Pure caffeine is a powerful stimulant and even very small amounts may cause an accidental overdose.

Our hearts go out to the Stiner and Sweatt families, and we appreciate their efforts to protect others from harm. As regulators, and parents ourselves, we take this threat to public health very seriously and are committed to protecting young people like Logan and Wade, and all consumers, from the dangers inherent in the use of powdered pure caffeine.

Michael M. Landa is the Director of FDA’s Center for Food Safety and Applied Nutrition

2014 Drug Approvals: Speeding Novel Drugs to the Patients Who Need Them

By: Margaret A. Hamburg, M.D.

Preliminary data announced earlier today shows that 2014 is shaping up to be another strong year for novel drug approvals, which is certainly good news for many patients and their families.

Margaret Hamburg, M.D.With a few weeks left in December, our Center for Drug Evaluation and Research (CDER) has so far approved 35 novel new drugs in 2014 compared to 27 in 2013. These numbers include both new molecular entities (NMEs), submitted to CDER in New Drug Applications (NDAs) and new therapeutic biologics submitted to CDER in Biologics License Applications (BLAs).

But the numbers don’t tell the full story. What really matters is that many of these new products offer significant clinical value to the care of thousands of patients with serious and life-threatening diseases. That’s certainly the case for patients with rare diseases that affect 200,000 or fewer Americans. So far this year we’ve reached a milestone with a record 15 approvals for rare diseases. The previous high was 13 drugs in 2012. These results are all the more significant because patients with rare diseases often have few or no drugs available to treat their conditions.

And here’s another point of interest – to date, 15 of the approvals have been first in their class drugs, another indicator of their potentially strong clinical impact.

To ensure that 2014’s novel drugs get to patients as quickly as possible, CDER effectively employed a variety of regulatory tools including FDA’s expedited development and review programs – fast track, priority review, accelerated approval and our new breakthrough therapy designation. Early and repeated communications with sponsors have also been helpful in speeding these products to market.

Consider for example, Blincyto, approved just last week to treat Philadelphia chromosome-negative precursor B-cell acute lymphoblastic leukemia. CDER employed all of its expedited review programs to help get this drug to market as early as possible, five months ahead of its review goal date. The sponsor also benefited from incentives for drugs that treat rare diseases.

Another example is Harvoni, the first combination pill approved to treat chronic hepatitis C virus genotype 1 infection and the first approved regimen that does not require administration with interferon or ribavirin. With this and other recent approvals, we are helping to change the treatment paradigm for patients living with hepatitis C. Harvoni received breakthrough therapy designation and was assigned priority review.

One of the more challenging areas of drug development has been the rather barren field of antibacterial drugs. Among our 2014 approvals to date are three new antibacterial drugs – Dalvance, Sivextro and Orbactiv—to treat skin infections, specifically acute bacterial skin and skin structure infections (ABSSSI). These drug approvals represent a welcome but modest increase in activity in this product area. Prior to 2014, only five new systemic antibacterial drugs were approved during the period from 2004 – 2013.

I want to congratulate the management and review staff at CDER for these very impressive preliminary numbers. Thanks in large part to CDER’s hard work and dedication, 34 of the 35 drugs approved so far in 2014 were approved before or on their Prescription Drug User Fee Act (PDUFA) review goal date and 23 of the 35 drugs were available to patients in the United States before they were available to patients in Europe.

In this holiday season of joy and reflection, we have much to be grateful for in the work that CDER does every day on behalf of patients.

Margaret A. Hamburg, M.D., is Commissioner of the Food and Drug Administration

Regulators Caught in the Act of Protecting Public Health

By: Melinda K. Plaisier and Michael M. Landa

We were ready to head out to observe the inspection of a Miami seafood warehouse, but another team of investigators asked that we first look at evidence from their last job. They showed us a video of a huge quantity of rice contaminated with live insects.

Melinda K. Plaisier is FDA’s Associate Commissioner for Regulatory Affairs.

Melinda K. Plaisier, FDA’s Associate Commissioner for Regulatory Affairs

Their work, they knew, would prevent that shipment from reaching consumers, and they were justifiably proud.

“Government regulation” is a term often used with derision. During a recent tour to observe investigators in FDA’s Office of Regulatory Affairs (ORA), however, the value of regulations was clear. So were the dedication, skill, experience, physical stamina, and pride investigators bring to one of the major steps in enforcing regulations. Those qualities appeared again and again–at a blood bank inspection in Boston, a juice facility in Philadelphia, an egg farm in Iowa, a smoked seafood plant in Seattle and at the Miami warehouse.

About 91 percent of the seafood sold in the U.S. is imported; 80 percent of that comes through Miami. ORA inspector Michael McCoy offered us winter parkas for the inspection in the cold storage warehouse.

McCoy, a marine biologist, formerly specialized in aqua farming and helped develop the process for farming shrimp, including the means to artificially inseminate them. He has worked for ORA for seven years. When he walked in the warehouse to sample yellowfin tuna from Surinam, someone announced, “It’s the meticulous one.”

From an even colder section of the warehouse, forklifts carried tuna-filled boxes called coffins, due to their size and shape. McCoy randomly selected 18 fish and from each one cut, from fin to belly, a sample. Then he weighed each piece before bagging and freezing it in dry ice for shipping to ORA labs in Atlanta. Inspection procedures call for one-pound samples. McCoy weighs each piece, but it turns out that in every case, he’s cut exactly one pound.

Just 24 hours after McCoy cuts the samples, the shipper learns the fish passed all tests and can be put on a plane to its buyer in Jericho, New York.

Michael M. Landa

Michael M. Landa, Director of FDA’s Center for Food Safety and Applied Nutrition

The cold warehouse inspection in Miami contrasts with the heat of an Iowa farm where 480,000 hens produce 144 million eggs yearly. FDA’s “Egg Rule,” or Title 21 of the Code of Federal Regulations, Part 118, is aimed at keeping the deadly bacteria Salmonella Enteritidis from the egg supply.

We travel deep into the countryside and up a long gravel road. In a “safe area,” we put on disposable Tyvek suits, including booties, hairnets, gloves and respirators. The suits are to ensure we don’t bring in anything to contaminate the area. At the door of the first of six henhouses, lead FDA investigator Katie Jo Close, a biologist, makes sure everyone walks through a box of powdered disinfectant—part of the farm’s biosecurity plan.

Sample collection requirements are exacting: for example, each swab for bacteria must be collected on a 4×4 inch, 12-ply gauze square that has been moistened with evaporated milk poured from a can whose lid has been disinfected with 70% ethanol. The protocols for where samples must be collected and how they are handled are even more exacting.

Before coming to ORA nearly six years ago, Close worked for a seed company, researching ways to make higher-yield, drought-resistant corn. Currently, in addition to inspecting egg farms, Close inspects facilities producing juice, canned goods and animal feed products, to name a few.

“I like the fact that each day is different,” Close says. “I feel like I’m protecting my family, my friends, my neighbors, everyone. I’m educating firms and farmers on how to follow the regulations that will prevent illness and death. I’m making a difference in people’s lives.”

From our desks in FDA headquarters, we see important work going on. Going into the field, though, is both humbling and inspiring. These men and women around the country, every day, are giving government regulations a good name.

Melinda K. Plaisier is FDA’s Associate Commissioner for Regulatory Affairs

Michael M. Landa is Director of FDA’s Center for Food Safety and Applied Nutrition   

Implementing the Unique Device Identifier System into health care systems is critical for reaching its potential to benefit public health

By: Jeffrey Shuren, M.D., J.D.

As the FDA works with manufacturers to launch a new system of identifying medical devices using standard bar codes and numbers, we look forward to the day when the system, called the Unique Device Identifier (UDI) system, will be fully set up— with identifiers on device labels and a corresponding database of identifying information about most of the devices in the U.S. marketplace.

But why does that matter?

Jeffrey ShurenMuch like vehicle identification numbers (VINs) for automobiles, UDIs are intended to streamline the monitoring of devices, improve safety tracking and recall efficiency, and even make it easier to evaluate device performance over time. So while there’s little doubt that UDI can improve patient safety, modernize how we evaluate devices once they are in use, and facilitate future device innovation, these benefits will only become a reality when the UDI system is adopted and integrated into the health care system—when hospitals, doctors’ offices, patient registries, heath care insurance companies, and others incorporate UDI as part of their standard electronic health information systems.

Without the practical implementation on the clinical side, UDI will be codes and a database with limited utility to improve patient care or reach its other critical goals.

The FDA is thinking about this now—not later. While going full steam ahead to fulfill our responsibility for implementing UDI regulations for medical device manufacturers, we are doing everything we can to promote the widespread adoption of UDI in the U.S. health care system.

We commissioned the Brookings Institution to create a “roadmap” for provider systems, patients, payers, supply chain personnel, and many others, to adopt and utilize UDIs. This report, released on Friday, December 5, provides 17 recommendations for adopting UDIs across three major intersections of the health care system—providers (e.g., electronic health records, hospital inventory management, billing records); administrative transactions (e.g., claims data and payment information); and patient-directed tools (e.g., mobile apps and public awareness campaigns).

We’re working hard to create and populate an efficient and useful UDI system for medical devices. But even the perfect system will fail to improve patient care if it’s not properly integrated into electronic health information systems. That process has to start now.

Today, we are co-sponsoring with Pew Charitable Trusts and the Department of Health and Human Services Office of the National Coordinator (ONC) a meeting where some 400 experts are convening to discuss changes that are needed to store and share UDI information throughout the health care system, with the ultimate goal of improving patient care.

The goal is to have the UDI system not only up and running—but actually used as the key to unlock important data that can help patients.

But how does such a system really help patients and the providers who care for them? Consider a possible scenario where the connections made via UDI could make an important difference in patient care.

A patient undergoing knee surgery—we’ll call him John—has the UDI of his knee implant scanned and electronically recorded into his clinical record.

When John is discharged, he can also register the UDI into his personal health record (PHR), available from his provider, through a variety of mobile apps that can enable two-way communication with his provider.

Having the UDI recorded will help John to know if safety alerts apply to his specific implant. It will also help him accurately report any potential adverse event to the provider, the FDA, or the manufacturer, with the confidence that the UDI ensures that all parties know what the type of device may be causing John—and possibly other patients—problems. Importantly, if John hears about knee implants being recalled, he will be able to quickly pinpoint, by using his UDI, if his particular type of implant is involved in that recall. If it’s not, John may avoid needless anxiety; if it is, he can take any necessary action, such as following up with his orthopedic surgeon.

The UDI from John’s surgery is also available to be transmitted to a total joint replacement registry, without any of his personal information. Data from the registry may then be used to support the development of innovative implants and reduce the data requirements for — or replace altogether — postmarket studies conducted by the device manufacturer to demonstrate long-term performance.

The possibilities of UDI are exciting—better and more precise information can lead to better care and better awareness of how medical devices work in the general population. The FDA is working to set up the system, but implementation and integration are critical. The question is—if we build it, will people adopt it?

Jeffrey Shuren, M.D., J.D., is Director of FDA’s Center for Devices and Radiological Health