It has been eight 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 2018 was the deadline to comply with the FDA's regulations. This week's tip offers a refresher on FSMA in an excerpt from an article written by Michael Koch of Morley Candy Makers/Sanders Candy for RCI's Kettle Talk magazine, plus tips for next steps.
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. FSMA requires that your plan be written and managed by a qualified individual. Individuals must complete a certification course to become a qualified food safety administrator.
PREVENTATIVE CONTROLS
Hazard Analysis and Risk-Based Preventive Controls (HARPC) is a documented food safety program that addresses hazard risks with preventive controls for every food product you handle in your facility to ensure it will not become contaminated and unfit for human consumption.
VERIFY EFFECTIVENESS
Continuing to verify 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 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.
WHAT NOW?
Co-chair of the FSMA Operations Team Steering Committee and director of FDA’s Food and Feed Program in the Office of Regulatory Affairs, Joann Givens shares next steps for food facilities now that compliance dates have passed for most small businesses.“The best thing that people in the food industry can do is take the measures required by the new rules – not just the letter of the law but what it represents in terms of transforming the food safety system. They should look at the big picture, at areas in which they could be vulnerable and proactively take action. Promptly responding to problems, even if they aren’t yet violations, can prevent them from getting to the point at which there is a concern about the safety of the food.”
Joann also stresses the importance of a thorough system for documenting what you do. “The better the records, the more a company can demonstrate that it is meeting the legal standard.” With the right processes and procedures in place you’re better equipped to prevent problems before they arise. Joann recommends creating some redundancy in your system, “if one measure fails, another can take its place.”
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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