This is the third 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.
For companies that don't have a solid HACCP plan in place or haven't started the transition to compliance with the new regulations, the prospect of FSMA compliance can seem overwhelming. Here are some tips for how to get started.
Break the rules into bite-sized chunks
Taken as a whole, the seven rules that make up FSMA can be pretty intimidating. The documentation alone is a lot to wade through.
A food safety consultant can facilitate your implementation process by breaking the rules into discrete, actionable steps.
Provide the necessary technical and financial resources for implementing the regulations
The cost associated with becoming FSMA-compliant is not insignificant. Developing a food safety plan, training, recordkeeping — these all require resources to implement.
However, the costs of getting FSMA compliance right are much greater than the costs of getting it wrong. The average recall currently costs the company $10 million, not counting the damage to their reputation. Non-conformances in less extreme circumstances can also be costly. If FDA inspectors uncover food safety problems, the rates for reinspection exceed $200 per hour.
Producers are also required to ensure test results derived from outside laboratories come from an ISO/IEC 17025:2005 accredited laboratory. Perry Johnson Laboratory Accreditation is an internationally approved organization that has accredited several food testing laboratories worldwide.
You can give your company an advantage by making a commitment at the outset to providing the resources necessary to succeed.
Perform a gap assessment
This is the first thing Perry Johnson's consultants do when they walk into a facility. A gap assessment measures a company's readiness for FSMA compliance by identifying the distance between where they are and where they need to go.
This process helps Perry Johnson determine the best implementation strategy and timeline. The approach is also cost-effective, as it allows companies to benefit from the systems they already have in place and make good decisions about how to allocate their resources.
Train your staff
Training is a necessary foundation for the success of any food safety implementation. Hayden notes that, especially if you don't currently have a solid HACCP plan in place, training is the place to start.
FSMA mandates that at least one person from your company (your designated Preventive Controls Qualified Individual) must attend the Preventive Controls for Human Food Training Course, which was designed by the Food Safety Preventive Controls Alliance (FSPCA) and recognized by the FDA. This is a three-day course, and most companies prefer to bring the training on-site for a group of employees.
But it doesn't stop there. A complete training initiative spans your organization, including educating your top level management. Rama Narasimhan of Perry Johnson Registrars Food Safety recommends: “Management and food safety personnel should have a solid understanding of Title 21, of the Code of Federal Regulations (CFR) Part 117.”
After completing the preliminary steps, it's time to take a deep-dive into food safety, which includes developing prerequisite programs followed by a HARPC plan.
After this is complete, you can move forward with developing the other facets of the plan to comply with FSMA. These include but are not limited to hazard preventive controls for processing the product, food allergens, sanitation, and the supply chain. You'll also need a recall plan.
Finally, it's important to recognize that food safety isn't something you can think about only when FDA inspectors are at your facility. It needs to be an ongoing commitment. Food safety consultant Wayne Williams suggests “creating a cross functional food safety team that meets regularly to maintain ongoing compliance.”
FSMA compliance deadlines are looming. In the next article in this series, we'll explore some resources that can help you in your journey to become FSMA compliant.