Wednesday, April 26, 2017

Tip #230: Refresh Your FSMA Knowledge


If you are in the food industry, chances are you are well aware of the Food Safety Modernization Act (FSMA). Now that HalloweenThanksgivingChristmasValentine’s Day…Easter is now over, this is a great time for a refresher in this excerpt from RCI's Kettle Talk, written by Michael Koch of Morley Candy Makers/Sanders Candy.

FSMA was designed to shift the focus on food safety from responding to contamination issues to a more proactive approach of preventing contamination before it happens. Through the passing of this law the FDA has gained more leverage in its ability monitor and control the safety of our food supply chain.

In September of 2015 the FDA finally published its “Preventive Controls for Human Food” guidelines. As part of the FSMA it outlines the mandatory requirements being placed on all food manufacturers.
The most important aspect of the law that everyone needs to realize is that it applies to all food manufacturers. If you think your company is too small and these regulations don’t apply to you, please understand you could be making a costly mistake.

As with many of the guidelines that the FDA enacts they have set forth a specific time frame for companies to comply. The timeline is as follows:


Prior to putting a plan together you must identify the individual or individuals in your organization that are going to administer your program. The FSMA requires that your plan be written and managed by a qualified individual. Currently the only way to verify that an individual is qualified is to have your food safety administrator attend a certification course.

Hazard Analysis
Hazard Analysis and Risk-Based Preventive Controls (HARPC) is a documented food safety program that you need to develop and implement for your facility. The first step toward developing a HARPC is to conduct a hazard analysis for every food product you handle in your facility—this is not limited to the items that you manufacture. The second step is to put in place preventive controls for each food product to ensure it will not become contaminated and unfit for human consumption.

Verification
Verifying the effectiveness of your plan ensures preventive controls are consistently implemented and sufficient. Verification includes evaluating the accuracy of process monitoring, calibrating instruments, such as thermometers, and reviewing records to verify monitoring and corrective actions are completed. Product testing and environmental monitoring by a certified third party are also reliable verification methods.

Recall Procedure
Your plan must contain details on your recall procedures. If a contaminated product is shipped, you must be able to identify where the product has gone and have the ability to perform a recall. A recall plan should include the procedures for identifying the contaminated product. Having important contact information in the plan will help move the process forward. Contacts should include the local health department, local FDA office, news media and anyone else that you may deem important to the process.

The FSMA covers a much greater spectrum of the food chain and more details than covered in this brief article. The realm of information and procedures that you are responsible for also cover such things as your supply chain management, good manufacturing practices, corrective actions and etc. The FSMA is no small task, it is designed to protect the consumer from obtaining contaminated products.

In order to operate a successful candy making business, it is essential that you are knowledgeable on federal regulations and take the proper action to ensure you are in compliance with FSMA guidelines. Visit fda.gov for more resources and updates.          

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