How to Prepare for the Food Safety Modernization Act

Last week, we had the great opportunity of having Judi Lazaro host our Food Safety Webcast. Her “how to” on preparing for the Food Safety Modernization Act, or FSMA, garnered much attention from our colleagues and customers leading up to the event. Judi walked us through all the key changes brought on by the FSMA and even pointed out regulations that our customers were already complying with. Feel free to check out the full text of the FSMA, a whopping 89 pages, or just check out a few of the major changes I've outlined below.

1.  Amendments to Section 402(2)(4)- the law now states that “A food shall be deemed adulterated if it has been prepared, packed, or held under insanitary conditions whereby it may have been contaminated or whereby it may have been rendered injurious to health.” “May” is the operative word here. Any reason to believe the food products may be contaminated is reason enough to consider it not fit for commerce.

2.  There are five key elements to the FSMA-           

• Prevention

• Inspection/Compliance

• Response

• Imports

• Partnerships

3.  Prevention- The FSMA has put a heavy emphasis on the prevention of any possible food contamination. Their five steps to prevention include: Hazard Analysis, Preventive Controls, Monitoring Effectivess, Corrective Action and Verification. Chances are, your food business already has these standards in place with your HACCP plans, but one major change is the addition of “radiological” hazards to your Hazard Analysis plan. And another thing to consider: how old is your hazard analysis and where did it come from? If it’s a plan you’ve been following for years “just because”, maybe it’s time to take another look and re-evaluate. These plans must be written down and backed up by science and common sense. Telling an inspector you clean your flour containers once a month just “because” simply won’t do.

4.  Inspection and Compliance- You must register your plant every two years. This is to be done during even numbered years between the months of October and December. By registering your plant, you give your consent for the FDA to inspect your plant. The FSMA permits access to all records related to manufacturing, processing, packaging, transportation, distribution, receipt, holding or importing of food if they have a reasonable belief that food has been contaminated. Make sure you have this information handy. In order to do this, designate a member of your team to do all the communicating with the FDA.

5.  Response- The FDA now has the authority to recall food products. Do you have the ability to recall your food products quickly?

6.  Imports- Know your suppliers! Have a written plan for assuring adherence to food safety requirements and make your food safety goals clear.

7.  Partnerships- You are encouraged to develop partnerships with State and local agencies in order to ensure that you are fully compliant and up to date on all standards.

If you have any questions about the FSMA, please contact us and we'll be glad to help.

Global Administrator