As the Food Safety Modernization Act (FSMA) compliance August 2017 date approaches, we would like to share with our readers how SQF Certification will prepare them to be FSMA compliant. Specifically, ‘What do I need to do to go from SQF Certification to FSMA compliant?” In a November, 2015 SQF Institute article (http://www.sqfi.com/2015/11/02/sqf-level-2-certification-gets-you-ready-to-be-fsma-compliant/), the Institute put forth an executive summary giving SQF Level 2 certified companies a path to FSMA compliance. The FDA will require a HARPC (Hazard Analysis and Risk-based Preventive Controls) food safety plan. The plan is a transition in approach to food safety. The focus is on prevention - rather than reaction. According to HARPC.com (http://www.harpc.com/harpc-requirements/), companies must create a written analysis of hazards and include both an identification of the risks as well as an analysis of the risks as they pertain (or could pertain) to the facility and the foods or food ingredients it handles. The core intent of the law is to identify hazards (biological, physical, and chemical including radiological) due to various processing, manufacturing, and packing activities. On the way to FSMA compliance, each food manufacturer must evaluate the risks for biological hazards such as Listeria monocytogenes, chemical hazards such as natural toxins, pesticides, allergens and food additives, and physical hazards such as shards of glass or other foreign material. In addition, the analysis also includes evaluating hazards that are introduced by acts of terrorism. Is the plant secure? Are security measures in place? Are personnel being screened? How safe is the entire supply chain from raw materials, ingredients and packaging and the finished goods received, delivered and shipped? As an SQF compliant facility, step 1 to prepare for FSMA compliance is to prepare a document that pulls together all the various aspects of a food safety plan, referring to all the SQF compliance information, and developing preventive controls that directly prevent the various hazards from occurring. To develop your preventative controls for each risk or hazard identified, consider these questions: - What training is in place to teach awareness of this risk? - What procedures are in place for prevention? - Are there physical barriers in place for prevention? (Doors, Keypad entry, lids, etc) - Are there technology (such as security rights access) barriers in place for prevention? Leveraging your existing SQF documentation and adding the preventative controls is your first step toward FSMA compliance. Next time, we will discuss the FDA’s two key activities food facilities must implement once a HARPC review and prevention plan is completed; namely, monitoring and verification. | Tamlin Software

Five Things Small Food Companies Should Know about FSMA Compliance…Today!

Compliance, Food Manufacturing, FSMA, GFSI, , ,

By Linda Bryan,
CEO, Tamlin Software

The first step isn’t always the hardest. Sometimes, in fact, it’s one of the easiest.

The Food Safety Modernization Act (FSMA) is a case in point. The final rules are in place, and deadlines are looming. And with its phased approach and extra ramp-up time allotted for smaller companies, the road to FSMA compliance may not be as bumpy as you think.

Here’s a quick overview of five key things small food processors and distributors should know to get the ball rolling on FSMA compliance:

1. Your first compliance deadline is August 30, 2017. The FSMA has set 8-30-17 as the deadline for small businesses to have preventive controls in place—a one-year extension over the general compliance period.

Small businesses are defined as those with 500 employees or less, and the ruling pertains to providers of human food as well as animal feed products.

2. Very small businesses have an extra year to meet the same standards. If you’re a very small producer, your deadline for having preventive controls in place is pushed back to August 30, 2018. The FDA defines a “very small business” as a human-food processor with less than $1 million in revenues, and an animal-feed company with less than $2.5 million.

3. Preventive controls address five core areas. The FSMA will require you to have measures in place to either prevent or minimize potential food-safety hazards in five specific areas:

  • Process
  • Food allergens
  • Sanitation
  • Supply-chain controls
  • Recall plan

4. Foreign-supplier verification deadlines can be tricky. The deadline for importers to meet FSMA compliance is a potential pitfall because it’s not only unspecified, the first deadline could actually come earlier than your own compliance date if you’re defined as a small business.

The deadline for foreign-supplier verification is April 30, 2017 to meet the general compliance standard. If you’re a small business with less than 500 employees, however, there is no special compliance period specifically set for foreign-supplier verification.

Yet, when no specific deadline has been established, you’re advised to follow the general compliance rule. That means even if you have less than 500 employees, you should consider April 30, 2017 as the final date for having all of your foreign verifications in place.

What’s more, if you’re a very small importer with less than $500K in revenues, the FSMA has also set April 30, 2017 as the deadline to ensure foreign-supplier compliance. As a result, all food companies regardless of size should view April 30, 2017 as the official deadline to verify your foreign suppliers are safe.

GFSI Standards are the easiest path to FSMA compliance.

5. And finally, satisfying FSMA guidelines won’t be so daunting if you’ve already got GFSI standards in place. In fact, if you’re meeting GFSI schemes today, you’re already around 90%-95% there as far as FSMA is concerned.

There are many advantages to having GFSI certifications in your arsenal, and a smooth transition to FSMA compliance is one of the best.

Questions about FSMA compliance or GFSI certifications—or both? Let us know by completing the form below. We’re happy to provide you with the answers.