Ten years ago, on January 4th, President Obama signed into law the Food Safety Modernization Act (FSMA). This act enables the FDA to better protect public health by focusing more on preventing food safety problems rather than simply reacting to them. Looking through a decade of U.S. regulatory challenges and achievements, so far, seven FSMA Final Rules and several guidelines have been published, and most food industries are already complying with the relevant requirements. Other FSMA compliance date deadlines to look out for are as follows:
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FSMA Final Rule
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Applicability
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Compliance Date Deadline
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Produce Safety
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Other Produce – Small Farms (remaining water requirements)
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Jan. 26, 2021
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Other Produce – Very Small Farms (remaining water requirements)
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Jan. 26, 2022
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Small Farms – Non-sprout agricultural water requirements
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Jan. 26, 2023
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Very Small Farms – Non-sprout agricultural water requirements
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Jan. 26, 2024
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Intentional Adulteration
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Very Small Businesses
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July 26, 2021
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For more current information on FSMA compliance requirements, visit the FDA’s website.
The battle is still far from being won – allergen labeling and management remains the top cited cause for product recalls, and contamination by Listeria monocytogenes and Salmonella continue to be the leading causes of foodborne illness outbreaks. These trends indicate that regulatory agencies, industry stakeholders, and allied groups should continue to make a concerted effort in providing safe and wholesome food to consumers. In light of increased hospitalizations during the ongoing pandemic, controlling for allergens and contaminants are even more critical as we face an already strained healthcare system.
This year should see significant activities centered around strengthening industry requirements toward FSMA compliance. The following are some of the recent developments to potentially keep track of:
- Collaboration and Integration within Agencies: Expect more open communication among North American regulatory agencies such as the FDA, FSIS, and the CFIA and stakeholders. One such collaborative initiative that has been spearheaded by these organizations is on Salmonella reduction efforts in meat, poultry, and produce to meet Healthy People 2030 global targets.
- Digitization of Food Safety Processes and Systems: To meet increasing record-keeping requirements, industries will make a greater effort to move away from physical paperwork and towards digitization and the use of AI and Data analytics technologies. Companies should be able to take advantage of real-time, block-chain, or predictive capabilities to help in hazard prevention, but these systems must also meet the 21 CFR 11 requirements on electronic record-keeping.
- Preparing for a New Era of Smarter Food Safety: The FDA’s Blueprint was launched in July last year as the agency’s master plan towards creating a more digital, traceable, safer, and FSMA-based food network system that should help bend the curve of foodborne illnesses in the U.S. We should expect more developments for this initiative in 2021.
- Traceability as a Preventive Approach: The ability to trace and track the source of foodborne illnesses to be able to better prevent future outbreaks has become one of the FDA’s priorities. This year we look forward to the finalization of FSMA’s proposed Rule for Food Traceability, which should mandate additional record-keeping requirements for certain high-risk foods.
- Enhanced Focus on Sanitation Controls: With sanitation being elevated to one of the hazard analysis risk-based preventive controls, there should be an increased industry focus toward an integrated sanitation approach. Such an approach should also include the selection, cleaning, storage, and maintenance of cleaning tools, as such equipment can also become vectors of contamination in a food plant.
For more updates on the FDA’s Viewpoint on FSMA progress and the path forward, visit the FDA’s website.
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