The 7 Pillar Rules are advancing into the final stretch. The FDA will have their action plan ready to implement in 2015-2016. Essentially, the gavel will hit the sounding block before the next Presidential election, or at the time the court-imposed deadlines approach.
Here are the court-imposed deadlines for the proposed rules within the Food Safety Modernization Act (FSMA):
| Preventive Controls (Human Food) | August 30, 2015 |
| Preventive Controls (Animal Food) | August 30, 2015 |
| Produce Safety | October 31, 2015 |
| Foreign Supplier Verification Program | October 31, 2015 |
| Third Party Accreditation Program | October 31, 2015 |
| Sanitary Transportation Program | March 31, 2016 |
| Food Defense | May 31, 2016 |
Larger companies will be given one year to comply after these rules are initiated. If there is still a question about your company’s compliance requirements, keep in mind that the FDA wants you to take a proactive, risk-based approach. So, step back and assess your company’s current systems and strategies. Create an FSMA Team, conduct a GAP analysis, and begin building an expedient, automated, preventive plan.
Conduct appropriate measures to determine if you need to make a few tweaks, or revamp a few areas within your organizational structure. You might need to overhaul your existing food safety plan and start from scratch.
There are many different software programs, compliance systems, and applications that can help you get through the most difficult stages of preparing your company for this transition. Depending on the prices your company can afford, or what you’re willing to pay, systems and processes will provide you ease of mind (i.e., a life preserver) in the event the FDA prompts your company to show that it crossed all T’s and dotted all I’s.
Here is a helpful link titled: 3 Critical Elements of Supply Chain Visibility for the FDA Food Safety Modernization Act (FSMA), which discusses major components to improve food safety. The article shows how this act gives the FDA the policing badge it needs to monitor food companies.
The FDA will assess your company to determine which risk category you fall under. It will consider:
- Whether your company has been part of a recall or outbreak in the past
- If the products your company produces are high risk
- If your products have ever returned positive results for pathogens
- Whether your company has been non-compliant or had FDA violations in the past
- Your verification of third party audits
- The effectiveness of your current risk-based hazard analysis program
If these tasks seem insurmountable, just remember the golden nugget at the end – compliance. Maintaining your reputation as a company having good business practices makes it well worth the time and investment.
