Clients and their domestic and overseas suppliers need to review all FSMA regulations to affirm which ones apply to them.  The link at the bottom of the article gives a listing of all the FSMA rules and associated guidance for industry.  The key ones that are most likely to out clients: 

  • Amendments to Registration of Food Facilities
  • Mitigation Strategies to Protect Food Against Intentional Adulteration 
  • Sanitary Transportation of Human and Animal Food
  • Food Supplier Verification Programs (FSVP) for Importers of Food for Humans and Animals
  • Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption
  • Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventive Controls for Human Food  and/or
  • Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventive Controls for Food for Animals
  • Information Required in Prior Notice of Imported Food  
     

Compliance dates are all over the map, depend on the size of the entity, vary from rule to rule, and a few specific individual requirement dates have been extended.  Suffice it to say that our clients may have some or all of these compliance dates in the future, but they are in the nearby future.  And the larger they are the more likely that some compliance dates are already in force.

Additional Information:

https://www.fda.gov/food/guidanceregulation/fsma/ucm253380.htm 

At (a nationally branded provider of baked beans), conducted vulnerability assessments on multiple sites using the FDA CARVER + Shock software tool, and created food defense plans based on best practices, company culture and a consensus among company participants.  This resulted in a common approach across the organization, and full adherence to the anticipated requirements of the Food Safety Modernization Act.

We have also taught Food Defense workshops all over the world with FBI, FDA, USDA and the State Department.  We reached over 35 developing countries and over 3500 participants.

At (more than one national manufacturer), led their nation-wide food safety initiatives to prevent food borne illness and assisted with certifying food and beverage plants in (Safe Quality Foods (SQF).

At (a major value-added salad producer), selected and led a team of experts in the evaluation and gap analysis of the company’s HACCP system across all salad facilities for purposes of strengthening and defending overall food safety and risk mitigation programs.  Developed customized analysis and reporting tools.  Prepared and presented integrated assessment report and future recommendations.

At the CDC, managed and executed the CDC priority to prevent food borne illness in schools by launching a nation-wide disease prevention program: The Food-Safe Schools Action Guide.  Facilitated workshops/ professional development sessions for target audiences [School Nurses, Principals, School Foodservice Staff, and Parent] amounting to greater than eighteen thousand attendees in eight years.

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