The new year marks the full implementation of the Food Safety Modernization Act (FSMA). The United States Food and Drug Administration (FDA) is moving forward with enforcement of these food safety rnvules. While the act was signed into law in 2011, several of the rules are in place and will be enforced in 2017. The big question now is exactly how the FDA will enforce these new regulations. That is why it is so important to research, plan, train and adjust with respect to compliance efforts.
First, keep in mind that there will be new fees under the FSMA for violations, reinspections, recalls and other related activities. Compliance starts as soon as March 2017 for some facilities. The severity of the fees varies, as the amounts are based on the number of hours spent on reinspections and compliance activities for each facility site. It's important to note, however, that criminal violations for non-compliance to FSMA begin with misdemeanor charges starting at $250,000 and up to one year in jail.
It is the responsibility of companies to develop the necessary programs to meet FDA Guidance Documents. Companies must move forward now to determine requirements and develop compliance programs. There are still legal approvals in place in order for the FDA to conduct facility investigations, issue recalls and implement other processes to ensure food safety.
Many food safety publications and websites have noted how these FSMA compliance rules will affect the various food industry segments — from companies working with fresh fruit and vegetables to smaller farms and businesses working with foreign-based food suppliers. For further reading, check out the recent FDA blog post, “First Major FSMA Compliance Dates: Landmarks and Learning Experiences”.
Second, act on the information you have. There are several key items to keep in mind: plan ahead, prepare your team and adjust/update your processes. Visit https://www.grainger.com/content/food-processing for more information and tips. To help prepare for rules implementation, it is important to update food safety plans. Review food processes for preventive hazards, and set aside some time to research published reports about food safety violations.
If you haven’t done so already, now is the time to put a designated compliance team in place to establish and reinforce food safety plans. It’s important to have a multifunctional team — from company leaders to supply chain and line workers — as this will help incorporate the safety procedures into the overall work culture.
The FDA lists the following key steps to keep in mind:
- Ensure that facility defense requirements are met.
- Verify that employees understand the company’s FSMA requirements.
- Review the company’s documented food safety plans, and look for gaps to address.
- Confirm that the company can provide the necessary documentation, if requested.
- Confirm that all company suppliers are effectively tracked, monitored and evaluated.
- Prove the ability to trace back products and conduct a recall, if needed.
Think about the entire supply chain, from every supplier and vendor to everything it takes to get the products on the shelves (or off if there is a necessary recall). Company staff need to understand where the risks are and, if appropriate, where controls are being implemented. Identify qualified individuals on staff who will help with food safety processes, and also make sure to have backup representatives available, since someone needs to be present during all food operations. It is also vital to keep the contact list updated and be prepared for a potential inspection.
Getting down to the food safety basics, here are some key activities to remember:
- Hand washing is a measure that prevents human contamination of food, which means making sure hand-washing stations are easily accessible.
- Installation of hand-sanitizer stations in areas between hand-washing sinks helps provide an expanded level of prevention against human-hand contamination of food.
- Better maintenance, conditions and sanitation help support preventive controls.
- Use multitiered maintenance carts to separate used and replacement tools to avoid cross-contamination.
- Create segregated storage for additional preventive control of chemicals.
- Review and update signage and warnings.
- Establish doorways/entryways to avoid contamination from footwear in a food facility including any chemical, biological, and physical or allergen contaminants.
- Conduct environmental testing for biological contaminant levels on food-plant surfaces.
- Use sanitation procedures for the transfer of food equipment to avoid contamination from microorganisms.
Remember, the main goal of the FSMA is to change the focus of food safety programs to actively prevent issues with food safety. It addresses the potential causes of foodborne illness outbreaks. Don’t feel overwhelmed; just start at the top of the list and remain vigilant with respect to planning, processes and overall safety.