· Hazard analysis and identification of preventive controls

-- Each registered facility will be required to conduct a hazard analysis of reasonably foreseeable hazards and put into place preventive controls designed to significantly minimize or prevent those hazards.

-- Each registered facility will be required to implement its preventive controls through a system that includes monitoring, corrective actions, and verification that the system is

working properly.

-- Finished product and environmental testing is considered part of the facility's verification process.

· Supply chain management

-- Supplier verification activities are expressly listed as one of the preventive controls to be implemented.

· Records maintenance and access

-- Each registered facility will be required to document its hazard analysis and preventive controls system, including corrective actions and product/environmental testing, and to make those records available to FDA upon request.

· Intentionally introduced hazards

-- Each registered facility will also be required to conduct a hazards analysis of those hazards that may be intentionally introduced, including those introduced by acts of terrorism, and to implement appropriate mitigation steps as deemed necessary by the FDA.

· Traceability

-- FDA will be required to conduct pilot tests and issue regulations for "high risk" products; the bill contains many restrictions on FDA's authority, including no "full pedigree"

requirements and an express exemption for "commingled raw agricultural commodities."

· Fresh product standards

-- FDA will be required to issue mandatory standards for "high risk" types of fresh fruits and vegetables and update its good agricultural practices covering the remaining product categories.