Adopting Global Food Safety Standards (Part II)

Suppose you are a manufacturer’s rep for a product that is needed by food processors facing the government’s new compliance standards under the Food Safety Modernization Act (FSMA). The client’s procurement manager tells you that his company already is compliant and has the certificate from something called FSC22000 to prove it. So why, he asks, do we even need new government regulations?

The question causes your head to spin:

  • Is the procurement manager correct, or is he smoking something?
  • What is FSC2200, anyway, and is it a substitute for FSMA?
  • Does my product meet the various food safety standards currently covering the food industry?
  • Can someone clear things up for me?

If this is you, or if you currently work in the food business, the chances are pretty good that you’ll face just these kinds of questions even as FSMA continues to roll out across America. How to make sense of the situation is the purpose of this post.

Voluntary versus Required

The first matter to keep straight in your mind is that there are many voluntary food safety certification programs and standards, but only one mandated law – FSMA. So, even if the company your work for has met those voluntary standards, your firm will still have to meet the new food law’s stringent regulations. But before you go off in a rage, it’s important to know that the voluntary safety standards by and large complement, and in some instances are incorporated into, FSMA.  So things may not be as onerous as you think.

Here’s why: the global food industry has taken clear leadership in creating food safety guidelines and standards for manufacturers, processors, suppliers in the food chain and food retailers around the world. These standards are rigorous, comprehensive and peer reviewed. They also are completely voluntary.

FSMA adds another layer of required compliance standards that in many ways reflect the industry’s standards. But it also adds record-keeping requirements that will force companies and their suppliers to maintain detailed records of preventive controls, safety reviews and inspections, and communications up and down the food chain.

Similarities and Differences

The food industry’s safety standards generally are organized into what are called “schemes.” Think of these as protocols or standards for the various procedures and practices of the global food chain. Example: temperature controls for perishable products. Each of the industry certification recommendations includes a set of established good manufacturing programs to insure that producers, shippers and retailers maintain constant and adequate temperatures to avoid food spoilage. So does FSMA, which also requires detailed record-keeping of temperatures for review by government inspectors.

Other similarities between industry voluntary standards and government regulations:

  • HAACP controls are prominent throughout all the food safety programs. FSMA’s are slightly different than the industry standards, but by and large, managing forseeable problems and dealing with them is a core concept underlying both the new government regulations and the industry programs;
  • Although different nomenclature is used, both the industry programs and FSMA emphasize the critical importance for companies to assign experienced food safety professionals to manage implementation and compliance efforts. The federal law calls these individuals “Preventive Control Qualified Individuals,” or PCQIs; the various voluntary industry programs also call for such individuals. Training for such designated individuals is widely available.
  • Food safety training is key to both the industry certification programs and the federal food safety law. The FDA has authorized dozens of training experts to conduct training seminars. Internet Google search lists numerous programs available for companies and individuals;
  • Perhaps the most significant difference between the voluntary programs and the government food safety law involves record-keeping. The industry programs lay out suggested actions a company should take to demonstrate proof of its compliance. FSMA, by contrast, requires companies to set up and maintain detailed compliance records that must be available on short notice for Food and Drug Administration inspectors. In fact, FSMA’s record-keeping requirements arguably are among the most contentious duties of the law.
  • One other difference is worth pointing out: the voluntary industry programs issue certification to those who pass muster. The FDA, on the other hand, does not certify manufacturers or suppliers as “certified” or “in compliance.” Practically speaking, this means that the industry certification can be used in advertising or marketing, but there is no such thing as FDA endorsement or certification.

It is important to note that as companies scramble to achieve compliance with FSMA, certification from a voluntary program can be especially helpful if for no other reason than to demonstrate to regulators that the company is serious about maintaining a high level of food safety protocols in its operation.

The voluntary standards are high-minded and tough. FSMA is tough and comprehensive. In the end, these standards are the most encouraging development in the long struggle to maintain a safe food supply.  The outcomes for consumers worldwide should result in fewer foodborne illness outbreaks and contaminations. That’s to everyone’s benefit.

 

 

 

Share