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Your Plant is FSMA Compliant, But Will That Save You From a Food Recall?

By: Mike Koeris on April 5th, 2017

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Your Plant is FSMA Compliant, But Will That Save You From a Food Recall?

FSMA  |  Food Safety  |  Food Recall

The FDA’s Food Safety Modernization Act (FSMA) is rolling out to companies large and small, and with the new compliance mandates comes greater responsibility on the part of food processors and manufacturers.

It’s big news in the industry, and hopefully you’ve implemented the requisite plans and procedures to meet the evolving demands of proactive food safety. But does FSMA compliance mean you’ve significantly lowered the risk of a food recall?

Unfortunately, regulatory compliance alone will not save you. Even if your plant is in complete accordance with all FSMA laws and guidelines, that doesn’t necessarily mean you’ve done enough to protect consumers and your brand.

There are a number of other critical factors that you need to consider in order to safeguard your company and your brand from the costly effects of a food recall.

Is your plant complying with proper food safety regulations and preventing a major recall?

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Reacting Quickly to Changes

FSMA laws have certainly brought about a massive shift in the food industry, requiring manufacturers to adjust their procedures for monitoring, testing, documentation and risk assessment. Monitoring for pathogens and deviations in the production environment must be a proactive effort.

Because of this greater focus on prevention and the higher standards for evaluation, food recalls will continue to increase in frequency. Greater contamination identification efforts lead to higher chance of finding actual contamination in testing samples -- a natural and desirable byproduct of more stringent approaches.

This is one reason why going beyond compliance is so important. In order to protect your company, it is essential to stay on top of the changes occurring as a result of FSMA compliance and execute processes to react quickly.

Fortunately, these same preventive techniques and testing advancements make it easier to respond to food safety issues in an efficient manner.

Environmental management software (EMS) can be used to react quickly if corrective actions are necessary when you get positive or unacceptable results from your environmental testing.

The ability to send out automatic email notifications to sanitation, QA and/or the plant manager when triggered ensures that remediations are completed and documented according to your food safety plan.

Implementing an Improved Process

To properly implement a new, stricter process for ensuring food safety and preventing recalls, every department should get on board and be empowered to gain a strong understanding of the overall effort. You must prepare employees for the changes going into effect.

It is essential to equip them with the proper knowledge and include them in the development of new plans. There must also be a seamless exchange of information between departments.

In terms of contamination prevention efforts, a lack of communication has the potential to cause mistakes that result in devastating product recalls.

Visibility and communication are major factors in achieving success and avoiding recalls. It’s wise to consider utilizing innovative food safety software that makes true visibility and open communication a reality.

With easy access to an organized database of policies, workflows and reporting, as well as automatic notifications and facilitated documentation, you give every department the visibility and communication tools they need to meet unfolding regulations and promote the kind of food safety culture that effectively mitigates the risk of food recalls.

Reviewing the Process Regularly

Now that you’re following new regulations through an improved process, it is vital to make sure that this process is constantly reviewed. Unless you remain vigilant about checking to see that the process is being followed across the board, you won’t gain much value from your new efforts.

Without regular review, you’re opening up your operations to costly recall-invoking errors, not to mention the risk of noncompliance.

As part of the review process, be sure to conduct third-party or in-house audits. “Food industry consultants and/or lawyers can visit your facility and play the role of the Investigator. Ask them to review your programs to identify possible regulatory shortfalls, and work with you to implement strategies that will strengthen your programs and reduce your regulatory exposure.” (Food Safety Tech)

Documenting All Your Efforts

Documentation is everything. If you’re not able to show proof of your new efforts to meet FSMA regulations, it’s as if you never took those actions at all. It’s crucial to have a system in place to verify that you are constantly performing preventive controls and that they remain effective. This is easily done with an EMS that enables you to build and deliver reports on the monitoring and corrective actions being conducted according to your food safety plan.

If you end up on the receiving end of an FDA audit, you’ll need to provide documentation for several aspects of your food safety plan, including your: HACCP/HARPC documentation, SOPs, routine testing results, investigative testing results and corrective actions.

The best way to accomplish this is by having it all digitally stored in a centralized database that can organize and produce the required materials in less than 24 hours. Documentation that’s stored and accessible in a pinch puts your operation in a better position to meet FSMA requirements and avoid recalls.

“More than ever before, the quality of the records will play a key role in whether a facility will be successful during an inspection by FDA. Since any record must be made available upon oral or written request, FDA has gained unprecedented access to written information. Such additional documented insights will assist an inspector in deciding whether appropriate measures were taken and documented to assure appropriate sanitary and food safety conditions during the manufacturing, processing, packing, or holding of human food. Any record failure associated with an issue critical for food safety will likely lead to official action and consequences.” (Quality Assurance & Food Safety)

Don’t make the mistake of thinking that being in compliance with FSMA gets you off the hook for additional efforts to protect the integrity of your product and prevent recalls. Make sure you are considering these other aspects in your food safety efforts.

Do you know what contamination identification and prevention actions are necessary to avoid a damaging recall? Download your free checklist: How To Find & Prevent Contamination in Food Processing Plants.

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