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Saturday, 31 January 2015

Readiness for FSMA, SFCA and Similar New Regulations

Are you ready? FDA still states that  "Human food companies other than small and very small businesses will need to come into compliance with the Current Good Manufacturing Practice, Hazard Analysis, and Risk-Based Preventive Controls for Human Food rule." This was initially set to be by September 19, 2016

Right on the heels of the Food Safety Modernization Act (FSMA) in the US, Reuters US reported that lawmakers propose bill to create single food safety agency. 

In Canada, the Safe Food for Canadians Act and Regulations (SFCA/Rs) are gathering momentum. These are only examples of the head-spinning changes that the food industry can expect in the next few years. The food regulations landscape worldwide will continue to change at dizzying speed as unfortunate food safety failures and food fraud events continue to occur around the world. 

The best that a business can do is retain a regulatory affairs manager who can get the business to a point of reasonable comfort about what is going to satisfy these new rules. More so since the rules themselves are continuing to undergo changes. Visiting inspectors are bound to have varying interpretations and the fun begins.

With the proposed mandatory registration and licensing, and the anticipated rush to obtain required licenses & comply with the new rules, Tiger Tamers are out in full force, armed with training sessions, seminars, webinars, et cetera. In the rush, none of these can even come close to covering the details in these new rules to which a company must pay close attention.

Everything that you need to know to prepare is provided in the Acts and Regulations. The SSQA Implementation Manual provides additional guidelines for getting the most out of any set of regulations. At no extra charge, the SSQA Manual also provides guidelines for developing a regulatory compliance and commitment program that equips you to address even future changes to regulations that are yet to be considered by the regulators.

Beware of Snake Oil Solutions:

Publicly offered webinars, seminars and training sessions are more likely to overwhelm you with copious ramblings about the new rules. They are not likely to provide any meaningful compliance or commitment strategy for your company. In fact, I am almost certain that they cannot. Such a compliance and commitment program is most effectively customized. No rushed generic training can effectively achieve such customization.

For several of the new rules, you need to carefully read between the lines (Food Law Page, Post 4) to cover the considerations that are specific to the type, size and scope of  your operation. The promises of getting your company ready to comply that may be offered by outside parties need to be carefully assessed to determine what they are actually able to deliver. I personally believe that you may be able to get more from participating in the public consultation invitations from the regulatory bodies than from any outside "consultant"or "trainer". Many of these are themselves trying to understand the rules.

Posted By Felix Amiri

Felix Amiri is the current Food Sector Chair of GCSE-Food & Health Protection

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