How to Implement FSMA
The first order of business for any organization is acknowledging the need to implement and comply with the act. Also, taking inventory of how the company stacks up at the present time is paramount to understanding what needs to be improved in order to become FSMA compliant. Often, companies are already in compliance with other food safety programs such as HACCP, with the FSMA being a “catch-all” for all programs under the food safety umbrella.
As far as implementation goes, there are a few steps involved. These steps are absolute catalysts for companies aiming to be 100 percent FSMA-compliant.
First Step:
The commitment from senior management must be apparent. First and foremost, there needs to be an amount of resources allocated for the incorporation of FSMA compliance. That means the necessary funding, employees, communication and general awareness. Once it is abundantly clear that management is committed to food safety efforts, they facilitate that commitment throughout the rest of the company. When management is 100 percent in support of necessary FSMA initiatives, the ball is rolling in the right direction.
Second Step:
Next, your company must attend preventive controls qualified individual training, or PCQI. Based on a mandate from the FDA, your organization must successfully complete training for risk-based preventive controls. In addition, the training must be equivalent to a curriculum that is officially recognized by the FDA, and no others. If this seems like a daunting task, companies are permitted to bring on a consultant as their PCQI. Any and all training conducted must also be documented with proper dates, type of training, and a detailed list of what employees received the training.
Third Step: Assessing the current state of the company to see which existing programs meet the preventive controls rule. This is in reference to the HACCP and HARPC Gap Analysis. Making sure your existing documents and programs comply or do not comply is important for understanding how much is in front of your company. The FDA has a few strict conditions when it comes to accepting existing records, as they must contain all the information that it deems necessary for 100 percent compliance.
Fourth Step: Creating a food safety plan that works for your company and employees. The first question a company must answer is: are they going to implement an entirely new plan or are they going to merge their existing plan to comply with the FSMA and augment where necessary. Regardless of whether you are creating an entirely new plan or enhancing the one you have in place, companies must place significant emphasis on preventive controls. The preventive controls must be up to the regulations and requirements as outlined by the FSMA.
Step Five: Keeping records of all training and certifications is critical for maintaining legitimate status with the FDA. To some extent, these records are proof of a company’s commitment to food safety. Having them on hand at all times keeps the FDA auditors at bay and holds employees accountable.
Following these steps will allow a company or organization to implement the regulations and requirements of the FSMA with the least amount of friction. As long as a paper trail is visible and easily accessible, the company can prove it has made strives to implement the FSMA to the best of their ability.
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