“Ensuring the safety of our products – and maintaining the confidence of consumers – is the single most important goal of our industry,” said Dr. Leon Bruner, Chief Science Officer for the Grocery Manufacturers Association (GMA), in a March 29, 2011 public meeting held by the U.S. FDA shortly after the Food Safety Modernization Act (FSMA) was signed into law. Five months later, the Washington, D.C.-based association submitted a document under the Federal Register’s FSMA request for comment provision for FSMA. The document is titled: GMA Food Safety Plan Checklist. (See download link at left.) To quote a passage in the introduction:
“This checklist is provided as an aid to companies that are developing a new Food Safety Plan or revising their existing plan to be compliant with the requirements in FSMA and the regulations and guidance developed from that law. This document is not a comprehensive document on ‘how to’ develop a Food Safety Plan nor a summary of legal requirements, but rather is a tool to assist in the many activities associated with plan development.”
The checklist is arranged in table form and organized under seven items or activity areas:
1. Preliminary Tasks: Inventory and assess current operations against FSMA requirements,
2. Hazard Analysis and Preventive Controls: Identify and evaluate potential hazards that are reasonably likely to occur and identify appropriate preventive controls,
3. Monitoring: Establish monitoring practices for each preventive control,
4. Corrective Actions: Establish procedures for corrective actions to be taken when preventive controls are not properly implemented or are found to be ineffective,
5. Verification and Validation: Establish procedures to verify that the preventive controls are effective and that the Food Safety Plan is working correctly,
6. Records: Establish effective recordkeeping procedures that document the Food Safety Plan, and
7. Training: Establish effective training programs for management and line-workers. If your company is required to have a food safety plan, the checklist is worth downloading for at least three reasons:
• First, the document is based on best practices already in place by leading food/CPG companies.
• Second, FSMA is based on the same best practices, making it very probable that if you follow it, your plant will likely be well on the road with FSMA compliance.
• Thirdly, if you don’t take a proactive role in following best practices such as those outlined in the checklist – and wait for FDA to publish a guidance document – your company may not only lag behind more sophisticated competitors; your company will be at risk of operating with substandard food safety precautions.
Additional, related resources can be found on the association’s website. Two FSMA-specific resources, in particular, can be found in the Food & Product Safety area of the site:
Both of these are free PDF downloads, and both are authored by Hogan Lovells (whose Elizabeth Fawell contributed to this Playbook).
Additional GMA resources:
• A Technical Guidance and Tools section of GMA’s website offers a wealth of technical
guidance on industry practices and regulatory compliance. Several links are provided and offered as free downloads. For example, a 34-page Food Supply Chain Handbook is offered in English as well as Spanish, French, Chinese and Russian. Other links include guidance on equipment design, salmonella control and facility design.
• A fully automated, online HACCP training course touted for reducing the cost of trainers, travel and related expenses through remote, 24/7 learning. GMA reports that this training courseware is “helping organizations of all sizes train employees at multiple locations, when needed, with fully centralized recordkeeping.
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