Though companies won’t need to comply with the just-released final Food Safety Modernization Act rule on preventive controls for human food for at least a year, retailers should start planning now, according to an FMI webinar.
“FSMA Finalizes Preventive Controls Rules: What Now?” — hosted by FMI and The Acheson Group and sponsored by ReposiTrak — discussed changes from the supplemental proposed rule to the final rule, and what companies should be doing to prepare.
The first step is creating a food safety plan.
“I would just get a plan together,” said Hilary Thesmar, FMI’s VP of food safety programs. “Get a plan down on paper. It can be a dynamic plan. It doesn’t have to be a plan that you stick with over the next year. But start small. Start with something manageable.”
Thesmar suggested beginning with the Current Good Manufacturing Practices programs, which should be familiar to food safety professionals and generally similar to practices already in place.
Those currently using a Hazard Analysis Critical Control Point plan or Global Food Safety Initiative-compliant plan may have less work to do to comply with FSMA.
“This rule actually recognizes that if you have a HACCP plan that actually addresses the requirements of the food safety plan or if you have a GFSI-compliant food safety plan under one of the schemes then you may be already there and/or only need supplemental changes to your food safety plan requirements to meet the requirements under this regulation,” said Melanie Neumann, EVP & CFO, The Acheson Group.
Companies should also begin identifying potential risks in their food safety systems.
“Start with that hazard analysis. And it’s not going to get done in a day or in an afternoon or even in a week. So much is riding on the hazard analysis in this final rule,” said Thesmar.
One thing that was not a change in the final rule but the webinar presenters said should be emphasized is that FDA has afforded flexibility in how companies can comply with hazard analysis requirements, depending on the products they process or manufacture, the type of facility, and the expected risks.
“And there isn’t ‘the way.’ There isn’t one right way to do it. That it’s flexible and FDA is really trying to get that message across,” said Neumann.
Making steps now to create internal protocols around FSMA will ensure that companies are fully prepared when the compliance dates come to pass, Thesmar said.
“There’s a lot of administrative things that have to happen to make this happen. So training, the records and documentation, you cannot build those overnight, so I would start working internally to make those programs happen now and build them slowly over the next year.”