Being Proactive in a Post-FSMA World

The US has one of the safest food supplies in the world, yet we almost always hear reports about a new crop of foodborne illnesses. These reports make national news and are eminently shareable on social media - not the kind of publicity any food producer wants.

AdobeStock_209650036-1To help prevent these incidents, Congress passed the Food Safety Modernization Act (FSMA) in 2011 which is now starting to be enforced. This new set of codes amended the Food, Drug, & Cosmetic Act of 1931. A big part of this act is the focus away from responding to food contamination and moving toward putting greater measures into preventing the contamination from happening in the first place. The act gives wider regulatory authority to the FDA in terms of inspection and recalls. 

Of note is Section 103 - "Hazard Analysis and Risk Based Preventative Controls" - which highlights ways in which the food producer is responsible to take a pro-active approach to preventing food contamination. This section states that "the owner, operator, or agent in charge of a facility shall... evaluate the hazards that could affect food manufactured, processed, packed, or held by such facility, identify and implement preventive controls to significantly minimize or prevent the occurrence of such hazards and provide assurances that such food is not adulterated...monitor the performance of those controls, and maintain records of this monitoring as a matter of routine practice."

Additionally, the FDA goes into more detail about hazard analysis in supporting materials. They mention that a good analysis must consider "known or reasonably foreseeable biological, chemical, and physical hazards" that can "occur naturally, unintentionally introduced, or intentionally introduced for economic gain."

The bottom line is that you need to be covering all of your bases when it comes to being proactive in preventing food contamination. Adding preventative measures like replacing existing cord drops and cordsets with anti-microbial wiring devices and electrical cable is an inexpensive step down the path to FSMA compliance. 

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