Clients and their domestic and overseas suppliers need to review all FSMA regulations to affirm which ones apply to them.  The link at the bottom of the article gives a listing of all the FSMA rules and associated guidance for industry.  The key ones that are most likely to out clients: 

  • Amendments to Registration of Food Facilities
  • Mitigation Strategies to Protect Food Against Intentional Adulteration 
  • Sanitary Transportation of Human and Animal Food
  • Food Supplier Verification Programs (FSVP) for Importers of Food for Humans and Animals
  • Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption
  • Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventive Controls for Human Food  and/or
  • Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventive Controls for Food for Animals
  • Information Required in Prior Notice of Imported Food  
     

Compliance dates are all over the map, depend on the size of the entity, vary from rule to rule, and a few specific individual requirement dates have been extended.  Suffice it to say that our clients may have some or all of these compliance dates in the future, but they are in the nearby future.  And the larger they are the more likely that some compliance dates are already in force.

Additional Information:

https://www.fda.gov/food/guidanceregulation/fsma/ucm253380.htm