The implementation of the Food Safety Modernization Act (FSMA) is coming, and as it approaches it seems like every day rules are being changed or added and businesses are often left wondering where to begin. The regulation is especially challenging because it brings together both food defense and food safety issues. In many cases, there are rules that are second nature for security professionals, while less familiar for food safety professionals, and vice versa. In an effort to ensure organizations are compliant, organizations should leverage what they already know to put practices in place for rules they are less familiar with.
In my experience working to secure some of the world’s largest food manufacturers, many are familiar with practices to prevent intentional adulteration – which is great. This knowledge helps to ensure compliance of the Proposed Rule for Focused Mitigation Strategies to Protect Food Against Intentional Adulteration. However, other proposed rules like the “Standards for Growing, Harvesting, Packing and Holding Produce for Human Consumption” are less familiar.
In many cases, by first becoming educated on the rule and thinking about successful practices for an area they are already familiar with, a business can get a head start. The Food and Drug Administration (FDA) has a site dedicated to FSMA, which provides guidance for the industry. It’s important for businesses to get to know the law and each of its rules. In many cases, not all rules will apply to every business, but by visiting the site businesses can narrow which rules concern them.
Next, businesses should take into consideration what’s been most successful in their food safety or defense initiatives. We often advise our clients to follow the Four As when building a proactive food defense plan. The methodology advises businesses to focus on assess, access, alert and audits. Food safety professionals familiar with HACCP will see similarities between food defense and food safety best practices. Once businesses have an understanding of which FSMA rules apply to them, they can think about past successful strategies, like the 4As, to create new plans that ensure compliance.
While many of the rules are still proposed and may change, it’s important that businesses prepare now. Through education and consideration of already known successful practices, businesses can ensure compliance when FSMA becomes effective.
Check back for my next post focused on what businesses should be doing now to prepare for FSMA.
