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WHAT YOU NEED TO KNOW ABOUT FSMA

While the act covers a multitude of areas concerning food safety, many regulations center primarily on prevention, chiefly the development of specific safety materials required for food facilities. Enclosed are some chief areas of concern when developing your organization’s food safety documentation.

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4. BUILDING PROCESS MAPS Documentation should include both building and facility maps, as well as process flow maps for food processing. 5. INVENTORY MANAGEMENT Maintain accurate documentation on how ingredients enter your facility and the location of all finished goods. +1 800 274 3978 www.rsmus.com RSM US LLP is the U.S. member firm of RSM International, a global network of independent audit, tax, and consulting firms. Visit rsmus.com/aboutus for more information regarding RSM US LLP and RSM International. © 2016 RSM US LLP. All Rights Reserved. ig-nt-tmc-cp-0616 REFERENCES 1 "Food Safety Preventive Control Plan Checklist," Iowa State University Extension and Outreach, Iowa Grain Quality Initiative, Department of Food Science and Human Nutrition, V. 2.1; Jan. 3, 2013. 2 "FDA Food Safety Modernization Act (FSMA)," U.S. Food and Drug Administration. Last updated Sept. 17, 2013. Accessed Sept. 25, 2013 via http://www.fda.gov/Food/GuidanceRegulation/fSMA/default.htm CONTACT JOHN MAJEWSKI AT [email protected] COMPLIMENTARY ONE-HOUR SYSTEM REVIEW: LEARN IF AND HOW YOUR CURRENT INFRASTRUCTURE SUPPORTS FSMA REQUIREMENTS. 6. RECALL ACTION Develop and implement a written recall action plan outlining procedures to follow for product tracing after distribution. 7. VENDOR MANAGEMENT AND APPROVAL Create a checklist for vendor approval and ensure the list is maintained. Key considerations should include the implementation of safe food handling practices and the level of risk posed by each vendor. Similarly, develop cleanliness measures to test against each vendor's transportation vehicle. 12. PEST PREVENTION Develop an established pest-control program to include periodic inspections, building adjustments to ensure pests do not enter facility and written records provided by pest-control personnel. 13. BIOSECURITY Your plan should include procedures to ensure against intentional contamination of food products. Such procedures may include measures to control employee building access after hours, passwords and locks on computer systems, employee background checks, and vehicle transportation control. 8. MEASURABLE TESTS Your organization should have in place detailed, documented tests to be performed on finished food goods to ensure against chemical and biological hazards. Tests should be measurable. 9. CONTAMINATION AVOIDANCE Develop written procedures for cleaning out containers and storage bins to ensure against cross contamination. Store all bulk materials in a manner that prevents contamination. Ensure all container labels are waterproof and environment-proof. 10. EMPLOYEE CONDUCT Safety documentation should include written policies on employee conduct and dress code, as well as procedures to follow concerning restrictions on employee work (i.e., regulations against eating, drinking or smoking while around food products or after contamination with infectious disease). Ensure all employees are trained on proper food conduct in accordance with the approved safety plan. 11. EQUIPMENT AND FACILITY CLEANLINESS Document cleaning procedures for both equipment and facilities. Sanitation processes may include scheduled clean-ups, a spill handling policy, hand-washing practices, and sewage and septic system inspections. WHAT YOU NEED TO KNOW ABOUT FSMA FSMA: WHAT AREAS DOES IT COVER? The Food Safety Modernization Act (FSMA), signed into law on Jan. 4, 2011, is focused on preventing, rather than responding to, contamination in the U.S. food supply. The act is divided into five key sectors, including prevention, inspection and compliance, response, imports, and enhanced partnerships. Each sector is further divided into subsections of best practices, covering all aspects of food safety management, as detailed below: 5. ENHANCED PARTNERSHIPS • State and local capacity building • Foreign capacity building • Reliance on inspections by other agencies 1. PREVENTION • Mandatory preventive controls for food facilities • Mandatory produce safety standards • Authority to prevent intentional contamination 2. INSPECTION AND COMPLIANCE • Mandated inspection frequency • Records access • Testing by accredited laboratories 3. RESPONSE • Mandatory recall • Expanded administrative detention • Suspension of registration • Enhanced product tracing abilities • Additional recordkeeping for high- risk foods 4. IMPORTS • Importer accountability • Third-party certification • Certification for high-risk foods • Voluntary qualified importer program • Authority to deny entry FSMA: WHAT YOU’RE RESPONSIBLE FOR While the act covers a multitude of areas concerning food safety, many regulations center primarily on prevention, chiefly the development of specific safety materials required for food facilities. Below are some chief areas of concern when developing your organization’s food safety documentation: FOOD AND BEVERAGE 1. SPECIFIED LOCATION The FSMA requires the development of a written food safety plan that details your company's procedures for: • Evaluating food safety hazards • Implementing preventive controls that will minimize or prevent hazards • Monitoring these controls to ensure their effectiveness • Maintaining routine monitoring records • Performing corrective action to address issues that arise • Identifying critical hazards and documenting how such hazards are controlled within your facility • Responding to chemical, physical or biological hazards • Physically separating incoming and outgoing food products • Responding to and mitigating consumer complaints 3. SPECIFIED LOCATION Your plan should be in an easily retrievable location, preferably in both a hard copy (physical location) and soft copy (network) format. The hard copy location should be waterproof, and all copies should be easily searchable. 2. MANAGEMENT IMPLEMENTATION Ensure you have management involvement in your food safety plan. This may be an individual or a team, depending on the size of your operation.