Are you prepared for the first Food Safety Modernization Act (FSMA) implementation deadline, coming up this September?

If you answered “no,” you're in good company. In a survey earlier this spring by SafetyChain Software and The Acheson Group, only 1 in 4 respondents said they were totally ready.

To help food processors and packagers — and their suppliers — better understand what's coming and how to prepare for it, we spoke with Carrie Hayden, President of Perry Johnson Food Safety Consulting, and some of Perry Johnson's trainers and consultants about issues they see surrounding FSMA implementation.

Over the next few weeks, we'll publish several articles resulting from these interviews. In this first one, we tackle some top challenges related to FSMA compliance and how to solve them.

Challenge #1: Lack of awareness

The biggest obstacle to FSMA compliance that Hayden and her team see is a lack of awareness about the new laws and what they mean in practical terms.

In particular, many small and mid-sized companies are still in the dark. Hayden said that Perry Johnson has been to SQF and GFSI conferences where their team has talked to smaller companies that have never even heard of FSMA.

This sentiment is echoed by Rama Narasimhan, VP of Product Safety and Research at Perry Johnson Registrars Food Safety and also an approved FSMA trainer. He notes that many companies are uninformed about the details of the new regulations. On top of that, even when they know about the regulations, they still don't understand how to implement them according to the timelines.

How to solve this challenge

Become informed! Many resources are available to help food companies understand what's coming and how to prepare for it, including the FDA and trade associations such as the FPSA. In addition, approved third-party trainers and consultants like Perry Johnson can provide resources and guidance to companies of all sizes that don't have the in-house expertise to understand and comply with the myriad new rules.

Challenge #2: Lack of management commitment

As with any new initiative, FSMA requires buy-in across the entire company, including at the top. Management support and participation, particularly during the implementation phase, is crucial to food safety plan success.

Narasimhan believes this is the key piece of the puzzle: “A company should start with top management's commitment to food safety as a written part of the mission statement. Without this level of support, the food safety plan will fail.”

How to solve this challenge

Provide awareness training for your senior management, and codify food safety into your company's value system. Once management is on board, they will become the best ambassadors for change throughout your organization.

Challenge #3: Lack of an adequate HACCP plan

FSMA requires a shift from the reactive HACCP (Hazard Analysis and Critical Control Points) to the proactive HARPC (Hazard Analysis and Risk-Based Preventive Controls).

A HACCP plan on its own isn't sufficient to comply with the new rules, but companies that have one are already on a good path toward compliance. The problem is that not all companies have an adequate HACCP plan as a baseline. This is especially a problem for small and medium-sized companies.

How to solve this challenge

If your facility doesn't have an HACCP plan, or does have one but it isn't adequate, you're already behind the curve for implementing FSMA. A food safety consultant can help you develop a strategic plan and implementation timeline to get you on track as quickly as possible.

Challenge #4: Lack of resources

Depending on your current state of compliance with HACCP, GFSI, and other food safety standards, FSMA implementation can be a major undertaking. And it requires both financial and technical resources, including staff, expertise, and time, that many small and medium-sized companies simply don't have available.

How to solve this challenge

FSMA compliance isn't optional, and the penalties for non-compliance are high. So, companies are well advised to put any and all resources they can toward accomplishing this goal.

However, they don't have to do it alone. Enlisting the help of external partners can put companies on the fast track to overcoming their expertise gaps. Perry Johnson food safety consultant Wayne Williams recommends hiring a reputable consultant to assist in gaining the required knowledge and becoming compliant.

Challenge #5: Lack of training

Training is tied to all of the other challenges on this list. But it's important enough to merit its own discussion.

In addition, the Preventive Controls Rule requires companies to have at least one “Preventive Controls Qualified Individual” (PCQI) on staff. A PCQI is someone who has completed the required training or who has industry experience necessary to design and implement a food safety program.

How to solve this challenge

At the very least, your facility's food safety practitioner, food safety manager, and anyone else responsible for the implementation of FSMA should attend a training course designed by the Food Safety Preventive Controls Alliance (FSPCA). This is important because these are the only courses taught by certified trainers and recognized by the FDA.

Many companies opt to train a group of employees, in which case the training can be brought directly to their facility. Partnering with a training organization like Perry Johnson will help you fast-track the process, and your company's progress toward compliance.

In the next article in this series, we'll explore some common misconceptions that are contributing to the lack of FSMA awareness and preparedness.