The Food and Drug Administration is seeking comments on its proposed approach for identifying high-risk foods.

According to the Federal Register, the FDA plans to accept comments on the plan until April 7.

The Food Safety Modernization Act requires the FDA to identify high-risk foods, according to the document. Under the law, high-risk foods are subject to additional record-keeping requirements.

Former FDA official David Acheson, president and chief executive officer of The Acheson Group LLC, said the biggest challenge the FDA may face is the question whether a high-risk food can ever be classified as a low-risk food.

“Can you get fresh produce, or certain aspects of fresh produce, from a high-risk (list) to a lower risk?” he said. “That's part of the challenge.”

No one in the food industry, including fresh produce, wants their commodity to be on the list of high-risk foods, Acheson said.

The FDA plans to publish a list of high-risk foods either before or at the same time it issues a proposed rule establishing record-keeping requirements for designated high-risk foods. The agency did not say when that will occur.

The FDA's draft approach to identify high-risk foods uses several criteria to determine a total risk score, according to the notice. However, no commodities were identified as high-risk in the FDA's initial document.

Some of the factors that FDA will weigh as it determines what are high-risk foods include outbreak frequency, illness occurrence, severity of illness, the likelihood of microbial or chemical contamination, potential for the food to support pathogen growth, food consumption patterns and the probability of contamination and steps taken during manufacturing to reduce contamination.

The FDA also will look at health and economic impacts, cost of illness, and disabilities expected, according to the FDA notice.