A Proactive Plan: The First Step to FSMA Compliance

It’s been about four years since the United States Congress passed the Food Safety Modernization Act (FSMA), and it’s finally time for the FDA to begin implementation of the requirements.

While there’s been some deadlines set, the finally deadline is set for May 31, 2016. At this final deadline begins the first steps of implementation of the new law. This law is useful for preventive controls for both human and animal food.

A lot of the law’s deadlines are schedule in the future, and specific details about the rules and who will oversee them, could change. There’s still a common them across all of the FSMA rules that those in the Food Industry, whether a supplies, part of the transportation process, or a seller: Be proactive in creating a food defense and safety plan. If you already have a plan in place, look at it and update it. That’s the first step to ensure compliance. If a proactive approach is taken toward food defence, it will make adherence to FSMA rules less daunting for organizations. It will also ensure that all of the businesses that are working to avoid any risks associated with food adulteration and contamination will be successful with implementation.

While planning, it’s important to keep the 4 A’s of food defense in mind:

  • Assess
    • Businesses should assess the risks in their supply chain. A great start is by conduct a vulnerability assessment of their critical control points to identify where someone could attempt adulteration – this includes inside the building, and anything that takes place outside the building.
  • Access
    • Organizations should be considering who, at critical access point has access. There are four key activity types that the FDA has identified that should be paid careful attention where they might be vulnerable to adulteration:
      • Mixing and grinding activities involve a high volume of food with a high potential for mixing in a contaminant.
      • Handling ingredients where there is open access to the product stream.
      • Loading and receiving of bulk liquids.
      • Storage of handling of liquids that are typically located in remote and isolated areas.
  • Alerts
    • It’s wise to implement technology that alerts the proper individuals or groups when there is intentional or even unintentional food adulteration. During this phase, response time is critical. Every passing moment is more time that health risks could develop, and that leads to a greater chance where there could be a negative impact on your brand, and more importantly, on the public.
  • Audit
    • Finally, the last area of planning, is auditing the operation and regulatory compliance  to ensure and maintain the best practices for food safety. This is also opportunity for documentation of compliance for regulators. You have to remember that prevention is only as effective as the processes appointed to remain compliant. A company should have scheduled and unscheduled compliance auditing in place. Using remote video technology for surveillance is a very effective way to confirm the appropriate practices are in place and working as intended.

A company not only needs to have a plan in place, they should also keep updated about the laws in place, and best practices for adherence to the laws to ensure their organizations are more secure in prevention of contamination issues.