The Challenge of FSMA Transparency

UPDATE

The critical importance of food transparency was underscored by the results of a recent global survey on consumer attitudes about overall food safety. Bottom line, confidence in food safety has declined, and consumers look to manufacturers and retailers to be proactive in preventing food contaminations and recalls. Read about the survey results here:

 

The new Food Safety Modernization Act (FSMA) presents food manufacturers and their suppliers with a significant challenge: how to efficiently filter FSMA preventative controls down the food supply chain to encompass the thousands of suppliers and vendors that will have to create and manage their own food safety plans?

The answer lies in a key section of FSMA, which codifies in its regulations the concept of “supply chain transparency.” Under the new regulations drawn up by the Food and Drug Administration (FDA), a manufacturing/processing facility must have a risk-based supply chain program for those raw material and other ingredients for which it has identified a hazard requiring a supply-chain applied control. In other words, at every step along the food chain from farm to table, manufacturers and producers must be fully cognizant of the safety controls of their suppliers – and have the records to prove it.

Actually, transparency has been around for several years in business-to-business circles. A series of disastrous food recalls traced to suppliers who either didn’t know what they were doing, or intentionally sold adulterated, unsafe product, prompted businesses here and abroad to begin putting their suppliers on notice: unsafe practices will not be tolerated. Under FSMA, manufacturers are obliged to hold their suppliers to the same food safety standards they must follow.

(Transparency and another descriptor, traceability, are often used interchangeably, but have slightly different meanings. Traceability usually describes the technical ability to verify the identity, history, location or application of an item, while transparency is used when talking about broader collaborations among trading partners in the food chain).

For the FDA, supply chain transparency is part of the agency’s new operating model that emphasizes strengthened collaboration and improved information sharing and gathering among trading partners, data-driven risk analytics, and the smart allocation of resources for food safety management.

food mfg close upThere are many places along the manufacturing production line where unintentional food adulteration may accidentally occur. Water used to hose down equipment may contain harmful bacteria. The lubricants used to keep the machines running at peak efficiency might touch the product as it whizzes by. And so on.

Suppliers of material used in manufacturing, such as lubricants, are required under FSMA to demonstrate that their products are properly formulated, labeled, stored and used to prevent compromising food safety, and that only “food grade” lubricants are allowed in those parts of the manufacturing facility where the food is produced. Lubricant manufacturers also must document their processes so that if a food safety problem arises, preventative control records and product formulations are readily accessible should a problem arise.

Over time, transparency will become second nature for manufacturers and their many supply chain partners. For the time being, however, companies all along the food chain are quickly realizing that the new way of doing business to prevent food contaminations will require time, attention and management focus not just inside their own operations, but also up and down the supply chain.

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