FSMA 2018 Update

With the effective date of the Produce Safety Rule in January 2018 all 3 food and feed rules are now in use and members of our industry are working hard to implement the requirements and understand the impact to their business.  While the programs and requirements may seem daunting it is very likely that your current activities meet the requirements of your associated rule and, with some ongoing documentation and training, your facility can consistently prove compliance and meet FDA visit requirements when they occur.

Preventive Controls for Human Food

Any food manufacturer required to register for the Bioterrorism Act of 2002 must become compliant with this rule.  The initial compliance dates for large companies was September 2016 and passed without significant issue.  Smaller organizations were expected to become compliant in September 2017 and, as this was the bulk of manufacturers, more challenges were identified with regard to availability of training.  Overall compliance and education continues with moderate success.

Preventive Controls for Animal Feed

Published concurrent with the Preventive Controls Rule for Human Food, this rule impacts all pet food manufacturers and animal feed mills.  Large facilities were tasked with compliance in September 2016 and was met with recognition that the industry as a whole was working diligently but required addition assistance and training.  Recognizing this, FDA has deferred enforcement of many of the food safety requirements, focusing on education and outreach in lieu of punitive actions.  It is important to note that while enforcement may be delayed, expectation of compliance remains.

Produce Safety Rule

Published in January of 2016, the very largest of the those impacted by this rule were required to be compliant in January 2018.  Of the 3 industry sectors the fresh produce industry is by far the most diverse in size and scope.  From individual farm stands to wholesalers and distributors sites must understand the requirements of the rule and the documents necessary to prove compliance.  Understanding of farm site risks and environmental, wildlife and input effects is essential to ensuring your farm is meeting the rule requirements.