Although the U.S. ethanol industry may be focused on the latest Renewable Fuel Standard proposal for 2017, ethanol plants need to remember upcoming compliance deadlines for the Food Safety Modernization Act, according to an article in Ethanol Producer written by Chris Bliley, director of regulatory affairs for Growth Energy.
The new regulations associated with FSMA — the first major update to U.S. food regulations since 1938 — will become effective in September, next year or even 2018, depending on the size of the facility. Large facilities have to have current good manufacturing practices (cGMPs) in place by Sept. 19, with compliances for preventive controls effective one year later. Smaller facilities with fewer than 500 employees must be compliant in CGMP by September 2017 and preventive control by 2018. Very small facilities with average sales of $2.5 million or less in the past three years have even longer deadline.
There are four major components contained in FSMA: risk-based preventive controls, inspection and compliance, imported food safety and recall authority. Bliley cautions that although it is only large ethanol producers that face upcoming compliance deadline, all plants need to think about the implications of FSMA.
Bliley said that plants will need “… a compliance plan that includes a hazard analysis, preventive controls, supplier verification, monitoring procedures, recall policy, corrective action and record keeping. A compliance plan requires standard operating procedures that address such things as personnel, pest control, water supply and plumbing, equipment and utensils and plant operations, among others.”
Whether plants must meet terms of the new regulations this fall or later, Bliley said they should be aware of FSMA requirements, as well as learning what their customers may soon demand in terms of compliance.