How to ensure an adequate food safety plan
Dr. Donna Garren from American Frozen Food Institute provides a step-by-step guideline on how to be prepared for when the government shows up.
Every day, we come closer and closer to the U.S. Food and Drug Administration’s (FDA) implementation and enforcement of new and complex federal rules, requirements, procedures and powers under the Food Safety Modernization Act (FSMA).
FSMA will transform the nation’s food safety system into one that is based on the prevention of foodborne illnesses. It will be a system in which the food industry systematically puts in place measures proven effective in preventing contamination. FSMA, which was signed into law in January 2011, represents the first major overhaul of the nation’s food safety system in more than 70 years.
And, because compliance deadlines for all of FSMA-related rules are final, now is the time to start taking steps to ensure your business has an adequate food safety plan in place.
Here is a step-by-step guideline of what to do to be FSMA ready.
Assess current standing. The first step is to assess where your facilities currently stand. To aid in determining your FSMA readiness, the American Frozen Food Institute (AFFI), McLean, Va., in partnership with the Seneca Corp., Vienna, Va., developed a unique FSMA Readiness Self-Assessment Program that is specifically tailored to help members of the food and beverage industry prepare for and adjust to this new food safety paradigm.
Launched in 2013, the program’s self-assessment tool provides facilities with readiness scores covering 11 separate operational categories, and indicates where action may be needed to ensure compliance with FSMA’s rule governing preventive controls.
FDA has indicated that the FSMA Readiness Self-Assessment Tool is a valuable training vehicle that helps food and beverage processors and suppliers prepare for the sweeping food safety changes associated with FSMA.
Comprehensive and easy to use, AFFI’s program provides a self-assessment report that examines hazard analysis, allergen controls, sanitation, recalls, current good manufacturing practices, supplier verification, corrective actions, validation and verification, monitoring, records and recordkeeping and training.
Once completed, the tool immediately generates and displays a facility’s self-assessment report and emails a copy of the completed report. Within moments, participants receive a clear picture of their site’s FSMA readiness and any steps necessary to ensure compliance. In other words, this tool will help companies understand how their facilities measure up against FSMA from every corner of the operation.
Prepare for inspection. After determining your FSMA readiness, there are several things you can do to prepare for inspection.
For example, use feedback generated from the FSMA Readiness Self-Assessment Tool to conduct a hazard analysis and develop a food safety plan that enlists risk-based preventive controls to prevent or mitigate risks identified in the hazard analysis.
Development starts by mapping out the production process and documenting contamination, adulteration risks and hazards that could potentially impact products throughout production.
Then, create a well-documented plan to implement controls to mitigate risks, and define corrective action that should be taken to address any problems derived from issues with the controls in place.
Record keeping and documentation is critically important. A good food safety plan requires supporting documentation such as scientific and technical information, including expert advice, peer-reviewed journal articles, scientific studies, agency issuances or other documents to validate its effectiveness. If scientific or technical information is not available or sufficient, FDA will expect companies to conduct studies to validate their preventive controls.
The food safety landscape as we know it will be drastically different after the implementation of FSMA, but knowing where you stand and having a plan in place will go a long way in ensuring your business is compliant.