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How to Prepare for the Food Safety Modernization Act
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Although the final language for the food safety regulations are far from complete, it’s important for food companies to take note that the Act will likely have an impact in 2011. Prudent companies will begin their response this year, rather than waiting and facing potential consequences.
At HCG, we believe there are two areas of immediate interest for food companies. These areas are (1) the requirement for risk based food safety plans and (2) the new authority for mandatory recalls. To be prepared, in 2011, food companies should focus on the establishment of a risk based food safety (HACCP) plan, ensuring a strong recall plan, and flawless food safety record keeping.
The area of greatest potential impact will be the requirement for a risk based food safety plan. Although the language of the Act does not specifically name Hazard Analysis and Critical Control Points (HACCP), HCG believes a HACCP Plan is the best, proven method to ensure food safety. In order to develop and implement a successful HACCP-based food safety system, it is essential to have properly trained personnel.
The second important requirement of the act will give the FDA authority to recall potentially hazardous products. While there are relatively few historical cases of companies refusing to recall suspect products in commerce, the Act will allow FDA to require a recall when there is sufficient evidence of a risk to the public. This implies two things for food companies. First is the importance of having a recall plan. A recall plan is more than the ability to trace food and packaging. A recall plan includes how to swiftly contact customers, remove food from commerce and destroy or recondition the product. When a recall takes place, actions must be swift. Companies that don’t have solid plans with internal and external communication systems, product control mechanisms and alternate transport or storage capabilities may face steeper expenses and an extended recall. Companies that are well prepared can minimize the financial, marketing and public food safety impacts of a recall.
Another area where improvements are needed comes from the fact that the act gives the FDA expanded authority to inspect records related to food. This will drive an immediate need for improving record keeping. A recall is an unfortunate and necessary action when errors are made or unexpected hazards are discovered. However, a recall may be required when product is suspect and cannot be proven safe through good records. This does not mean the product itself is known to be unsafe. It means the company failed to keep records needed to prove the product is not adulterated. If product becomes suspect due to a complaint, a regulatory observation or a call to an FDA or other hotline, companies must be prepared to prove the status of suspect products. If this is not possible, a recall may be required at significant loss to the company. HCG expects an increase in recalls due to this factor. This can be avoided with better record keeping.
The HACCP Consulting Group promotes and offers practical and personalized services to assist clients maintain compliance with regulatory changes such as this new act. For information on HACCP courses, please contact us. We can provide on-site or public courses or refer you to an internet based introductory or refresher course. HCG also has available a generic recall program that can be adapted to your company’s needs. We do not believe in selling ‘canned’ programs. We work closely with our clients offering a starting point and custom tailoring it to an effective program. We also are developing an internet based course on good record keeping. Please watch for details in our future newsletters.
Cathy Crawford
HACCP Consulting Group
(phone)757-357-5654
(cell) 757-371-5832
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