If only they used HACCP - US food safety moving from reaction to prevention

In the US, the Food Safety Modernization Act (FSMA) will fundamentally change food safety for food processors as the focus will shift from reacting to contamination incidents to preventing such incidents.

Although the FSMA was signed into law in the US in 2011, it has not been fully implemented via regulations yet and many stakeholders across the food industry appear to be confused about implementation deadlines, according to a recent study from PMMI, The Association for Packaging and Processing Technologies. Compiled from 64 interviews with manufacturing professionals, the report details food manufacturers’ perceptions of FSMA and how equipment manufacturers can best help them respond to the upcoming regulations.

FSMA requirements will be performance based. That is, the FDA will not set specific standards for processing and packaging equipment; rather, regulations will focus on the performance that companies are required to achieve. This gives companies latitude in how they will meet the new requirements. For example, some companies will install new machinery, while others will attempt to squeeze acceptable performance out of legacy equipment with modifications and upgrades.

The three aspects of the FSMA that are most likely to impact both food producers and equipment manufacturers include rules governing:

• Preventive control
• Recordkeeping and traceability
• Sanitary equipment design

Preventive control rules are likely to have some of the earliest and most significant effects on food producers. These rules state that:

• Each facility in the food supply chain must implement a written food safety plan that focuses on preventing hazards in foods.
• Operators of each facility need to understand the hazards likely to occur in their operation and to have preventive controls to minimise or prevent the hazards.

Although traceability is expected to represent one of the greatest costs of FSMA compliance, the food industry generally recognises at least two benefits that will result from successful systems:

• Modern traceability systems can reduce liability. A company with proper systems can show precisely which supplier shipments it took in and where products went, potentially reducing its exposure to mandatory or widespread recalls.
• When recalls do occur, traceability systems can make these recalls ‘surgical’, with only affected products having to be pulled from shelves.

Four different technologies could greatly increase traceability capabilities among food processors and manufacturers, including:

1. Barcoding: Machinery that scans barcodes from bags of ingredients, tracks what ingredients are going into individual batches, and records and collates that data centrally.
2. 2D Matrix codes: 2D matrix codes can carry much more data than standard barcodes and will likely speed up and simplify traceability and recall efforts due to the ease of scanning versus manually reading production codes on finished product.
3. RFID tags: Tags that would provide the same sort of information advantages as barcoding, but without the need to physically scan labels. Some respondents believe that RFID may not be a good solution because too often water and metal in products and packaging interfere with the signal.
4. Integrated unit tracing options: Equipment that could automate applying lot labels and recording corresponding database entries.

The PMMI’s study identifies the industries most affected by the anticipated rules. Fresh produce manufacturers are expected to see the greatest impact. Producers of baby food, infant formula and nutraceuticals will see little impact as they have already been subject to rigorous standards for preventive controls, traceability and sanitary equipment design. Industries overseen by the USDA are less likely to be impacted and juice, low-acid canned foods and seafood manufacturers are exempt.

The report also expands on ways that manufacturers affected by FSMA can make strides towards compliance - whether they have one, two, three or four years to do so. These steps include reducing liability with greater traceability capabilities, evaluating equipment design for improved sanitary construction and easy cleaning, and training operators thoroughly and often.

“Since 2011, FSMA has been a source of anticipation and anxiety for many food and beverage manufacturers. The legislation can impact companies differently depending on their size and vertical market,” says Paula Feldman, director, business intelligence, PMMI. “Our aim with this study was to shed light on industry concerns and advise manufacturers on ways they can ensure compliance.”

Australia and New Zealand are not exempt from impact from the FSMA as future food safety laws are expected to address importing issues even more vigorously