Staying Ahead of the Food Safety Modernization Act (FSMA)

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Food Safety and Food Quality are receiving more attention today than ever in the history of the world. Vital to protecting the food supply are major, recent food safety and food quality measures that will bring forth the highest quality, safest products to date. If you are reading this blog you've likely already heard of the Food Safety Modernization Act (FSMA) and are probably well aware of its sweeping implications for your food-related business. However, if not, the goal of this short article and its accompanying video is to serve as both a “heads up” and a resource pathway for getting to compliance.In exploring this subject I had the opportunity to meet with and interview Kris Crabb, the Director of Compliance at Portco Packaging. Aside from having a solid command of all things safety and compliance related, Kris is a Preventive Controls Qualified Individual (PCQI) certified through the “Food Safety Preventive Controls Alliance” (FSPCA). Kris summed things up early with the following statement:[su_quote]The FDA has passed the largest reform in American history in over 70 years with the creation of the Food Safety Modernization Act (FSMA). FSMA was passed on January 11th, 2011 by President Barrack Obama with the primary goal of shifting from a reactive approach of responding to contamination to a proactive approach in preventing it from ever taking place.[/su_quote]In what amounts to a zero tolerance program for food safety, systems must be in place to check and correct ALL possible points of non-compliance. This means BIG changes for many in the food industry. Image Courtesy: Portco.com 

New Rules Coming

While the video below paper goes into greater detail about FSMA and what it might mean for your business, here are a few quick bullets to pay attention to as well:

  • Preventive controls are one of the major elements of FSMA that require comprehensive, prevention-based control across the entire food supply (including food packaging entities) to minimize, and in many cases eliminate, possible food safety risks.
  • FSMA includes inspection and compliance where industries are held directly accountable and carry complete responsibility in producing safe food.
  • Imported foods are also subject to FSMA compliance as they now must also meet the standards for consumer use within the U.S. The standard moving forward will be that an accredited third party certification is required as verification to ensure imported food meets American standards.
  • Another major change with FSMA is that for the first time ever the FDA now has power to issue mandatory recalls for all food products. FSMA introduces legislation that focuses on the importance of partnerships between food safety agencies such as the U.S. federal, state, local, territorial and tribal food safety officials.

    •  Portco Packaging is well ahead of the game having FSMA compliance in-place before even required. Also an SQF Level 3 certified facility, Portco prides itself on not just compliance, but leadership in food safety. Image Courtesy: Portco.com 

    Key Implications of FSMA for Food Packaging Suppliers

    Before you jump to the video below, I just wanted to touch on one other important element that I learned about in my interview with Kris Crabb. Specifically, I am talking about the regulations surrounding foreign suppliers. Many food packaging companies, Portco included, order and utilize products from outside the U.S. in their processes. A key implication of FSMA for companies supplying food packaging is while the FDA does not consider food packaging to be defined as “food,” the FSMA Foreign Supplier Verification Program (FSVP) (FSMA Section 301; FFDCA Section 805) does. Thus, there are several key factors that must be understood for these types of business:

  • Food packaging companies do not fall under the HARPC for we do not manufacture process, pack, or hold human food for consumption in the United States. This means food packaging companies do not need to register as food facilities under Section 415 of The Federal Food, Drug, and Cosmetic Act (FD&C Act). Further, packaging companies do not need comply with HARPC requirements and can remain under HACCP based practices.
  • In contrast to the HARPC rule the FSVP includes the term “food” when talking about food packaging materials as packaging is indeed a food contact substance (FCS). Thus, food packaging is included within the scope of the FSVP rule. Simply put, if you are an importer of food packaging materials, FSMA requires an FSVP.

    • Well, that should be enough to get your attention if this subject has flown under the radar at your company or organization. And for those of you already in compliance, “hats off!” For the rest, please enjoy the video below as well as the links throughout this post to take your awareness even higher. 

    Video: A Look at FSMA by Portco's Kris Crabb

    This video features Portco Packaging's Director of Compliance, Kris Crabb, exploring some high level elements of FSMA and how they may affect your food-related business: [su_vimeo url="https://vimeo.com/177764981" width="640" height="360"] 

    Additional Resources

    As noted at the tail end of the video featured above, there are several additional resources we encourage you to explore to get a more custom and complete understanding of what exactly the Food Safety Modernization Act may mean to your company. Here again are those links and best of luck in compliance!

  • FDA http://www.fda.gov/Food/GuidanceRegulation/FSMA/ucm239907.htm
  • Food Safety.gov https://www.foodsafety.gov/
  • SQF Institute http://www.sqfi.com/suppliers/fsma-resource-page/
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