Human food perspective on new food safety law

Today the Institute of Food Technologists, based in Chicago, held a forum/live webcast with several experts on the human food industry weighing in on the new US Food Safety Modernization Act of 2010.
 I'll share more highlights once IFT makes the presentations available, but meanwhile, I thought this insight from one of the speakers, Tony Pavel of K&L Gates LLC, was interesting:
 He commented that most of the large, recent recalls in human food that garnered a lot of media attention were not cases of in-plant contamination; rather, contaminated substances (ingredients or other materials) were brought into the plant in each recall situation.
 Pavel is an expert on HACCP (hazard analysis and critical control points) plans, and one of the key provisions of the new law is that all food producers required to be registered with the Food and Drug Administration -- which will now include most petfood manufacturers -- will be required to have some sort of risk-based, preventive control plan in place.
 What struck me about his comment is that many petfood recalls come about because of the same scenario: Contaminated ingredients or other substances are brought into the facility. This was the case with the massive 2007 petfood recalls, in which wheat flour (mislabeled as wheat gluten) was contaminated with melamine. And it was also the case in the most recent large recall making the news, when corn grains contaminated with aflatoxin entered a plant making Kroger petfood products.
 Which makes traceability up and down the supply chain and verification of supplier safety all the more important, right? (And all that is also part of the new law -- more on that to come soon.)