HACCP Update: Regulatory Compliance

This article originally ran in the July/August 2012 issue of Food Manufacturing.

The HACCP Update section of Food Manufacturing is designed to offer our readers insight into the state of HACCP implementation and compliance across the Industry. We received hundreds of responses to this month's survey on regulatory compliance.

Last year’s Food Safety Modernization Act (FSMA) mandated HACCP planning across all industry segments, increasing the regulatory burden for food manufacturers.

When Food Manufacturing last surveyed its readers on regulatory compliance issues in HACCP planning, survey respondents reported almost complete support for mandated HACCP plans. As shown in the chart below, this support has not waned. Though 78.3 percent of those surveyed report making changes to their HACCP plans in order to stay in compliance with the FSMA, this survey’s results are in line with past HACCP surveys that show food processing personnel broadly support HACCP regulations.

Before the FSMA, only meat, poultry, seafood and juice were required to write HACCP plans for their facilities. When asked if broadening this mandate to all food processing facilities was a fair change, 91.9 percent of survey respondents said “yes.”

In fact, when asked about their general view of food safety regulations, very few processors feel put-upon by government oversight. Food processors report believing:

• There is too much regulation—12.9%
• There is not enough oversight in food manufacturing facilities—25.8%
• The regulations governing food safety are a good fit for the industry—61.3%

Further, 80.6 percent of Food Manufacturing readers report a belief that the FSMA will improve food safety across the industry. However, though there is broad, industry-wide support for the FSMA, food manufacturers may report feeling a bit rudderless in navigating the new regulations. When asked, “Do you feel the FDA is providing enough guidance to prepare food manufacturers for the new requirements under FSMA regulations,” 63.9 percent of survey respondents said “no.” This figure is actually up slightly from last year’s response, when the regulations had only been law for a few months.

When asked an open-ended question about how regulation by state, local and federal regulators impacts processing, two common responses overwhelmed the survey data. First, most surveyed report that regulations have little impact on their facilities, as they are currently operating at or above regulatory expectations. Second, many processors report frustration with convergent regulatory expectations from different bodies. It appears as though a normalization of food processing regulations across all levels of government could help to clarify food safety and HACCP standards.

As in surveys past, food processors report  changing HACCP plans for various reasons (as seen in the graph above) and with the assistance of various industry experts. When consulting with outside experts in writing and evaluating HACCP plans, food manufacturers report that their most valuable sources are:

• Internal QA/QC experts—75.0%
• 3rd party/customer auditors—50.0%
• USDA/FDA auditors—45.0%
• Paid consultants—26.7%
• Equipment manufacturers—20.0%
• Other—5.0%

Despite some uncertainty over implementation and frustration with uneven regulatory expectations, food processors broadly support mandatory HACCP planning and food safety regulations and call upon a large stable of experts to help keep them in compliance.