How the FSMA Wants Your Workers to Fight Intentional Adulteration
Bill Bremer, Principal, Food Safety Compliance, Kestrel Management
The Food Safety Modernization Act (FSMA) is bringing changes to virtually every aspect of food production in America. While the Act has a broad mandate to prevent food contamination, the FSMA's provisions for the prevention of intentional adulteration have the potential to be the most impactful.
The FSMA now requires that food companies put in place a food defense plan to prevent contamination and adulteration. That plan, however, will be implemented by your workers and their supervisors, who have critical responsibility for its success. Particularly in cases of intentional adulteration, these employees could be the only way for your company to learn of suspicious action. With a clear understanding of your food defense plan and their responsibilities under it, they can prevent your operations from being subject to violations and punitive action while increasing overall food safety.
Providing Safety Strategies
As your eyes on the ground, your workers have the unique ability to spot and report issues before they become problems. Strategies for food defense can help ensure that you get information on cases of adulteration fast, and that your team can respond appropriately.
The U.S. Food & Drug Administration (FDA) provides clear guidance on exactly what workers should do to keep food safe and prevent incidents. Called FIRST, the program asks food workers to:
- Follow company food defense plan and procedures
- Inspect their work area and surrounding areas
- Recognize anything out of the ordinary
- Secure all ingredients, supplies, and finished product
- Tell management if they notice anything unusual or suspicious
A team following FIRST guidance will be able to report issues fast, keep their workspaces and facilities secure, and develop a habit of food safety.
The FDA and the Department of Homeland Security have also put together the See Something, Say Something campaign. It aims to raise awareness of common signs of adulteration, including behaviors and actions that are questionable. Workers are prompted to report suspicious behavior immediately, monitor their workstations for signs of adulteration, and keep their work areas secure and clean. Post these resources beside your plan, giving workers easy access to help in preventing adulteration.
Sticking to the Plan
Your team may already practice common strategies for preventing intentional adulteration, but under the FSMA, they now must be able to demonstrate all aspects of a sound food defense plan. Every team will need access to the strategies and requirements of your plan to defend against intentional adulteration that they can reference. This means documenting your food defense plan in a highly visible way.
Provide your team easy access to the plan to prevent intentional adulteration, and offer frequent opportunities for continuing education. This can take the form of a volunteer food safety team, monthly or quarterly trainings, internal certifications, or similar events.
With visibility into the plan, your team can be proactive about solving problems, instead of guessing at, ignoring, or missing sources of adulteration.
Supervising the Process
Your supervisors play a big role in preventing intentional adulteration. As your first level of management on the ground, supervisors take on responsibility for monitoring their entire area and reporting up any suspicious behavior or issues immediately. The supervisors you have in place will need to adopt FSMA rules as part of their function, and implement small-scale policies that help avoid adulteration.
While you cannot keep an eye on every process and facility, your supervisors can have direct visibility over their area of operations. Supervisors can execute the food defense plan while providing leadership in their department, adjusting individual behaviors or escalating reported issues to avoid cases of adulteration. Preventing adulteration requires a cycle of vulnerability assessment, monitoring, and mitigation that supervisors will need to lead.
This balance of authority and responsibility keeps FSMA rules in check. Supervisors are your second defense against cases of adulteration, managing sick employees, escalating issues, and addressing non-compliant processes every day.
Training and Certifying
The FSMA also requires that workers taking part in food storage and processing seek specific food safety certifications. These certifications are more than just a slip of paper, and help your workers prevent and report cases of adulteration.
Being proactive about this training can help alleviate future issues in tracking and reporting intentional adulteration. Your team will be more prepared to prevent the leading causes of adulteration, from sickness to terrorism, and will know what to do when problems arise.
Drive your organization to invest in these new standards early, and ensure that those working with food have some level of expertise in preventing adulteration. Early training can go a long way toward later prevention.
Implementing Quality Assurance
While good planning and team responsibility can prevent many incidents, checking in on the process is a great way to prevent issues from developing over time. Quality assurance dedicated to FSMA compliance can serve as a final defense against intentional adulteration.
While your team still bears the responsibility for preventing intentional adulteration, QA can audit the process to see how the rules are enforced. Randomized QA removes variability and bias in the application of your food safety program, and reveals gaps and inconsistencies that supervisors can help mitigate. Having an outside team specifically tasked with applying FSMA intentional adulteration regulations to the supply line can prevent these overlooked issues from becoming catastrophes.
FSMA and intentional adulteration rules will require wide-ranging changes to any organization handling food. While rules are in place to keep food safe and pure, your company will need to apply new strategies to prevent the causes of adulteration. A mix of FDA and internal strategies can make adulteration less likely while increasing overall food safety.
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