The Food Safety Modernization Act (FSMA) is no little-known piece of legislation in the industry today. As the defining rules have been finalized – and compliance dates have come and gone – manufacturers everywhere have felt the pressure of regulatory change. But is everyone on the same page when it comes to understanding these “new” compliance requirements? How is your company approaching its FSMA compliance obligations, and do you believe that technology can help? In October 2018, Food Safety Magazine published insightful survey responses from over 200 processors in the U.S. and Canada regarding this particular issue. About 70 percent reported being confident that they are in compliance with FSMA, yet only 30 percent said that FSMA had caused them to implement specific changes. When asked what those changes were, the most frequent answer was “more testing.” These numbers show a stark contrast between what manufacturers think about the requirements of FSMA compliance and what that compliance actually entails. They also shed some light on why so many food companies have overlooked the importance of integrating food safety technology into their compliance approach.
As the FDA explains, “Congress enacted FSMA in response to dramatic changes in the global food system and in our understanding of foodborne illness and its consequences, including the realization that preventable foodborne illness is both a significant public health problem and a threat to the economic well-being of the food system.” The seven major rules outlined within FSMA show the multifaceted and complex nature of food safety, instituting heightened regulation in the areas of:
- Preventive Controls for Human Food
- Preventive Controls for Animal Food
- Produce Safety
- Foreign Supplier Verification Programs
- Accredited Third-Party Certification
- Sanitary Transportation
- Intentional Adulteration
As the world evolves and food supply needs transform, players across the industry are charged with employing more modernized systems for preventing contamination and foodborne illness. The question of compliance, then, becomes this: What are you doing to modernize your approach and adopt a more advanced, effective means of ensuring food safety? And, more specifically, have you underestimated the importance of utilizing technology in this effort?
Garnering Insights and Visibility
Think about your current FSMA compliance efforts, and ask yourself whether you have a solid system in place that enables the team to:
- Visualize the entire plant with regard to preventive controls and corrective actions
- Quickly communicate results and actions across departments
- Leverage automated notifications that keep everyone apprised of important alerts and information
- Ensure that your environmental monitoring program is properly scheduled, monitored and reported on
If you can’t say with great certainty that your system is capable of achieving these essential elements of insight and visibility, you haven’t fully modernized and adapted your compliance strategies to meet the needs of FSMA. Relying on outdated, manual processes simply doesn’t cut it any longer. You need the right kind of technological support to maintain full and steady compliance.
Automating Data and Reporting
How are your teams reporting on sampling data, testing results and corrective action records? Are they able to:
Store all sampling data, testing results and corrective action records in one easily accessible location? Quickly locate data and compile automated compliance reports? Instantly see locations and patterns that may need to be addressed in the food safety plan? Extract hidden insights and trends that support risk reduction?
When it comes to achieving FSMA compliance, it’s critical to adopt a solution that keeps you and the necessary team members fully informed on the performance, risk and mitigation information you need on demand. You should be able to funnel food safety performance data from multiple manufacturing facilities and supplier sites to all players in the quality, safety, and compliance value chain. Simply put, you need technology that can automate food safety and has the intelligence to:
- Aggregate your data, or combine food safety test results from multiple sites to obtain a complete picture of your food safety risk
- Analyze your data, or conduct discovery activities by effortlessly interacting with the data set in real time via drill-down and drill-through functionality
- Act on your data, or investigate trends and outlier results to immediately take action before problems can cause major compliance issues and recall consequences
Systematizing Action Plans
Are you implementing action plans that meet FSMA compliance obligations and prioritize the safety of consumers? As sweeping reform has mandated a more proactive approach to food safety, you must be able to take swift and effective action to manage hazards, respond to nonconformances and prevent future occurrences. There’s a seemingly infinite number of real-life instances that prove failures to correct contamination issues in the production process cause serious compliance challenges. The good news is that modern food safety technology safeguards against these failures and reduces overall risk. How much more confident would you be in the fulfillment of your FSMA obligations if you had the support of a technological solution that has mapped the full corrective action process to its software functionality? Your action plans would be automatically streamlined and error-proofed via a process that looks something like the following:
- The presumed positive triggers a corrective action, for which the
- predetermined responsible individual is automatically notified by email.
- The user is prompted to complete each of the steps in the process and has
- the ability to attach lists, pictures, meeting minutes or any other relevant
- After the initial SOP steps are completed, the re-test is automatically
- scheduled. (If multiple re-tests are required by protocol, the auto-scheduling
- can be customized accordingly.)
- Upon completion, the results (including an audit trail of each step taken, at
- what time and by whom) are available for review and fully documented for
- historical purposes.
Even if you believe that you have a comprehensive food safety approach in place, there are always opportunities for deviations from the established processes to occur. That’s what makes corrective action plans supported by systematic technology so vital to FSMA compliance.
Training Teams and Unifying Standards
The operations that unfold within your company rely, to varying degrees, on human effort, which always comes with a risk of error. That means it’s critical to ensure that all members of your organization are trained in food safety procedures and in utilizing the technology to support those procedures. Intelligent software can standardize many of the processes your teams are responsible for carrying out, serving as a pillar of risk-reduction. Even so, it’s necessary to have a dynamic and ongoing training effort in place to equip people with the knowledge and skills they need to succeed within your food safety and compliance program. Consider whether you have a full, accurate picture of the training activities being executed in some of the following areas:
- Personal hygiene
- Chemical handling
- Quality assurance
- Control point testing
It’s essential to designate a team or individual to oversee the training initiative and maintain the company’s commitment to compliance. Also, consider the importance of training in any search you undertake to identify the right food safety technology for your organization. You’ll want to be confident that the solution provider will be thorough in their rollout of the technology, including valuable training for the people who will be responsible for using it.