With the first year of the Food Safety Modernization Act (FSMA) in the books and another round of compliance dates just around the corner, a list has been complied of the top five recurring themes and lessons learned in the food safety industry. Keeping the below points in mind can help you continue to navigate FSMA and understand how it has impacted the industry thus far.
- Don’t scrap your current plan
Many in the industry have questioned throwing out their current food safety and/or HACCP plan and starting a brand new “FSMA plan” from scratch. Food Safety Tech urges you not to do this because chances are if you care about quality and food safety, you already have effective quality management systems in place. It would be a disservice to the company and the general public for all these time-tested plans to go straight into the bin, the article explains. It is more realistic to take a look at the current system in light of the new regulation and ask yourself if there are any gaps that can be addressed.
- Education is key
A compliant system cannot be developed without an understanding of the requirements. Although FSMA is derived from the basic principles of HACCP, there are key differences. It is important to understand not only the updated Good Manufacturing Practices and Preventive Controls for both Human and Animal Food, but also the Foreign Supplier Verification Program, Sanitary Transportation and the Produce Rule (if they apply). Although the FDA-recognized curriculum for some of these companion regulations have not yet been released, some independent training providers are offering workshops to help fill the gap while the FDA and FSPCA are working on the official curriculum.
- “You must evaluate if you need it.” Not the same as “you don’t need it”
Some training providers have told their attendees that they can scrap many of their current systems because FSMA is less stringent than schemes approved by the Global Food Safety Initiative (GFSI). However, different certification bodies do not care how stringent FSMA is (as long as you are compliant with its requirements, as local regulatory compliance is a key factor in GFSI approval). FSMA will not change expectations related to the GFSI-approved food safety schemes.
The article also explains it is misleading to think that because FSMA can be flexible, FDA regulators will not have expectations of excellence when they arrive at food processing facilities. This law gives regulators the power to take legal actions to address many infractions they have seen over the years but have been powerless to stop; the flexibility may well be a double-edged sword in that regard. Ensure that all decisions are based on data and records exist to validate any claims.
- An ounce of prevention is worth a pound of cure
The entire purpose of FSMA is to shift the focus of food safety from reactive to proactive. Historically, the safest products to buy were those from companies with recent major recalls, as every process at the company is under a microscope for some time after such an unfortunate event. However, that’s really an unsafe way to play, and tells you more about what the United States didn’t have before, in terms of regulatory presence and capability. By shifting focus to prevention rather than detection after the fact, we engage the core tenet of HACCP in its most basic form. There are decades of data to demonstrate that prevention works, and the proliferation of HACCP-based systems in companies around the globe, even those that lie outside the food sector, shows it is a workable way of preventing issues.
- Attitude is everything
In some cases there has been a combative relationship between FDA regulators and professionals in the industry, with each feeling the other side is aggressive and unnecessarily difficult. Remember, the FDA is doing their part to promote a more open system of communication by sending their inspectors to public PCQI classes, holding webinars and other training sessions, and introducing tools like the Technical Assistance Network to help individuals who have questions about the regulations. At the end of the day, we must work together to be successful.
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