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

Take the First Step to move from SQF (Level 2) to FSMA

Compliance, Food Manufacturing, food processors, FSMA, GFSI, , , ,

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.