This is the second article in our series about FSMA and food safety based on interviews with Carrie Hayden, President of Perry Johnson Food Safety Consulting, and several members of Perry Johnson's training and implementation teams.
The previous article in this series explored five major challenges to FSMA implementation that Perry Johnson's trainers and consultants encounter when they talk with food manufacturers and their suppliers. The first — and most significant — of those challenges is a lack of awareness about what the rules are and what they mean for particular companies.
In this article, we build on the awareness issue by clearing up three common misconceptions about FSMA.
Misconception #1: We're already GFSI certified and have a HACCP plan, so we're all set
According to Rama Narasimhan, VP of Product Safety and Research at Perry Johnson Registrars Food Safety:
“There is a general misbelief in the industry that GFSI certification is a guarantee that a company will meet the requirements of the new FSMA regulations. While, in principle, this is correct, companies have to do a lot of homework to meet the specific requirements.
The Preventive Controls for Human Food regulation is conceptually different from the conventional HACCP approach to food safety. Just because a food processing company has implemented and certified to one of the GFSI standards doesn't mean they will be able to meet the FSMA regulations in total.”
If you are certified to a GFSI standard, such as SQF, you already have a robust food safety system in place that has been verified by a certification body. This is a great start! It means you are much closer to meeting FSMA requirements.
But it's not sufficient. The whole goal of FSMA is to change the focus from how food companies respond to problems to how they prevent problems. This requires a shift in mindset, as well as new written food safety plans and systems for monitoring, verification, and corrective actions when things go wrong.
To meet these requirements, Narasimhan recommends companies get their staff trained on the new regulations and/or seek the help of experts.
Misconception #2: We don't have to worry about FSMA compliance yet
Many companies are taking a “wait and see” approach to FSMA compliance. But with the FDA putting more resources into inspections and enforcement, companies that wait too long could find themselves the recipients of hefty fines.
Narasimhan clears up this misconception with regard to the Preventive Controls Rule:
“At this point, small businesses (those employing fewer than 500 full-time equivalent employees) have to be compliant by September 18, 2017. Very small businesses, basically those that average less than $1,000,000 per year in sales (there are other conditions that must be met), need to be compliant by September 17, 2018. All other businesses need to comply by September 19, 2016.“
If you haven't taken steps toward FSMA compliance yet, now's the time. The next article in this series will provide advice on where to start.
Misconception #3: We can do it alone
If you have trained and experienced food safety experts in-house, you might be able to do it alone. But for most companies — particularly small and medium-sized ones — the knowledge gap is too wide to tackle on their own.
Carrie Hayden notes:
“The effectiveness of a food safety system lies with the folks that know it best. As an approved training provider, Perry Johnson recognizes the importance of training personnel so they are equipped with the knowledge to develop and maintain a robust food safety system.”
Do any of these misconceptions ring a bell? If so, they could be getting in the way of your company achieving FSMA compliance in time for the approaching deadlines.
In the next article in this series, we'll outline some starting steps for companies on their journey to become FSMA compliant.