It has been seven years since the Food Safety Modernization Act (FSMA) was signed into law, which also means if you manufacture food and operate with less than $1 million in sales, September 17, 2018 is the deadline to comply with the FDA's regulations. This week's tip offers a refresher on FSMA and its requirements in an excerpt from an article written by Michael Koch of Morley Candy Makers/Sanders Candy for RCI's Kettle Talk magazine.
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| Click here for further clarification on compliance dates. |
WHAT
IS FSMA?
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 published its "Preventive Controls for Human Food" guidelines. As part of FSMA, it outlines the mandatory requirements being placed on all food manufacturers to have and implement a written food safety plan.
Before putting a plan
together, first, identify the individual or individuals in your organization
that are going to administer your program. 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.
IDENTIFY HAZARDS
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.
VERIFY PLAN’S EFFECTIVENESS
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.
CREATE RECALL PROCEDURES
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.
FSMA covers a much greater
spectrum of the food chain and more details than covered in this brief post.
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 and 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. Click
here for more resources and updates.
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