Charting a Smart, Efficient Course to FSMA Compliance

by | Sep 1, 2016

Food Safety Modernization Act (FSMA) RizePoint

Like every government regulation, the Food Safety Modernization Act (FSMA) is dense and complicated—with hundreds of rules and requirements, rolling implementation timelines and enough legal jargon to make even the most dedicated food safety expert’s eyes glaze over. But complicated or not, FSMA is here to stay, and as more requirements take effect, it’s starting to make a serious impact.

So what’s the best way to understand FSMA—and start coming to terms with its complex and still evolving requirements? That’s obviously a broad question with an answer that could easily fill volumes. But sometimes, it’s helpful to step back and look at the big picture. Because although FSMA is certainly far-reaching and complex, most of its requirements fall into a few relatively simple categories that naturally lead to a series of logical steps. By understanding these higher-level “pillars of FSMA” and how they apply to your business, you can begin to demystify and make sense of FSMA regulations—and develop an achievable roadmap for compliance.

So here’s a quick summary of these key “pillars of FSMA,” along with a few suggestions for applying them to your organization.

1. Perform a Detailed Hazard Analysis

If you’re in the food and beverage industry, you almost certainly have a food safety program in place. However, FSMA changes the game by shifting the focus from simply limiting the scope of contaminations to preventing them from occurring in the first place.

To make sure that shift takes place, FSMA requires you to perform a thorough written Hazard Analysis that documents potential hazards that could affect your manufacturing processes, sanitation efforts, and supply chains.

You can choose to perform this Hazard Analysis internally, engage outside food safety experts, or both—as long as the final product meets specific FSMA regulations and requirements. Basically, this Hazard Analysis exercise is designed to help you proactively identify and address significant food safety hazards before they lead to outbreaks or other issues. And even more important, it forms the foundation for your FSMA compliance efforts.

2. Develop Effective Preventative Controls

After you perform a thorough analysis to determine which food safety hazards qualify as “significant” for your organization, you can design and implement specific preventative controls to address them. These controls generally address four main categories—processes, sanitation, food allergens, and suppliers.

In some ways, FSMA preventative controls are similar to the Hazard Analysis and Critical Control Points (HACCP) system you may already use, but FSMA controls typically go above and beyond these standard critical control points. The preventative controls you define and implement should also include specific parameters for controlling all of the significant hazards that might affect your business. These controls essentially make it possible to turn the findings of your written Hazard Analysis into meaningful processes and actions.

3. Oversee and Manage Your Compliance Efforts

Performing a thorough Hazard Analysis and defining effective Preventative Controls requires careful thought, planning, and expertise. When those pieces are in place, you can begin to monitor the effectiveness of your preventative controls, take corrective actions, and carefully document your efforts. Traditionally, food and beverage companies have used a variety of different approaches to manage and document their food safety efforts—from manual checklists and rooms full of paper records to various spreadsheets and custom databases. However, as more Food Safety Modernization Act requirements take effect, you should carefully consider moving to a unified, purpose-built software solution that can provide more advanced auditing and verification capabilities.

4. Verify the Safety of Imported Foods

Until recently, there was really no reliable way to make sure imported foods met U.S. safety standards. FSMA addresses this issue with a Foreign Supplier Verification Program (FSVP). If your business imports food, FSMA requires you to conduct a hazard analysis, evaluate your foreign suppliers’ safety performance, and verify their FSMA compliance.

In many ways, the FSVP mirrors the steps you use to assess, monitor, and verify your own compliance, so it makes sense to simply extend these same compliance processes to foreign suppliers. Once again, the right kind of auditing and compliance software platform can make this a much simpler exercise.

Begin Your Successful FSMA Journey Today

Of course, I don’t want to oversimplify or understate the scope of FSMA. Making the shift from reactive to proactive quality management certainly requires new ways of thinking, higher levels of commitment, and significant technology investments.  But I also believe that wrapping FSMA requirements in these broader, more approachable categories can help you achieve compliance more confidently—and make it possible to chart a smart, efficient course through the sea of FSMA details.

For more information, read our FSMA Ebook here!

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