If you are in the food industry, chances are you are well aware of the Food Safety Modernization Act (FSMA). Now that
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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