The Food Safety Modernization Act (FSMA) was touted as one of the biggest reforms in the history of U.S. food safety when it was signed into law in 2011 — and for good reason. FSMA put a strong focus on prevention of foodborne illnesses by placing greater enforcement authorities into the hands of the FDA. Yet, the immediate impact was minimal. The FDA was given the authority to initiate a food recall, but the preventive rules were yet to be written and funding hadn’t been fully implemented. Since then, those rules have been crafted and are now mandatory. While many food producers, distributors and transporters have proactively implemented plans to comply with new laws that will come into effect in 2017 and beyond, many more must prepare for what’s coming.
New Laws and Compliance Dates
The FSMA required food organizations to comply with new preventative measures one year after their final posting to give companies time to implement the proper practices and procedures. Smaller businesses are given two years to prepare, while very small businesses have up to three years to get up to code. Some compliance dates are further out than the standard prescribed time allotment.
Here are several laws the FDA will begin enforcing in 2017 and beyond:
|
Food Safety Modernization Act: Specific Rule |
Final Posting |
General Deadline |
Small Business |
Very Small Business |
|
Preventative Controls for Human Food |
8/30/15 |
8/30/16 |
8/30/17 |
8/30/18 |
|
Preventative Controls for Animal Feed |
8/30/15 |
8/30/16 |
8/30/17 |
8/30/18 |
|
Produce Safety |
10/31/15 |
12/31/17 |
12/31/18 |
12/31/19 |
|
Foreign Supplier Verification Program |
10/31/15 |
4/30/17 |
4/30/17 |
4/30/17 |
|
Sanitary Transportation |
3/31/16 |
3/31/17 |
3/31/18 |
<$500k N/A |
|
Food Defense |
5/31/16 |
7/31/17 |
7/31/18 |
7/31/19 |
An important FSMA rule that goes into effect on April 1, 2017 is Sanitary Transportation of Human and Animal Food. The rule covers anyone involved in the shipping, receiving, loading and carrying of food in the U.S. (and to be distributed in the U.S.) by motor or rail vehicle. The key points of this rule include:
- Vehicles and transportation equipment must be designed for easy cleaning and maintenance to safely transport food.
- Transportation operations must provide adequate measures to ensure food safety, including proper temperature controls, protection from cross-contamination, prevention of ready-to-eat food from touching raw food and prevention of food contamination from non-food items in the same — or previous — load.
- Training carrier personnel in sanitary transportation and documentation of training.
- Written maintenance records of all food safety procedures for up to 12 months.
This rule is an extension of safeguards originally envisioned in the Sanitary Food Transportation Act of 2005. It came forth following illness outbreaks that were attributed to human and animal food that was contaminated during transportation. Small businesses employing fewer than 500 people and motor carriers with less than $27.5 million in annual receipts have until April 1, 2018 to comply with this rule. Food transportation operations with less than $500,000 in annual revenue are exempt from this rule.
Step One: Make a Plan
As is the case with following most new rules, the first priority for any business is to make a plan. In the case with FSMA, it is required. Food facilities must implement a written preventative controls plan.
It starts with evaluating hazards in the facility that might affect food safety. The next step is to specify the preventative steps or controls that will be put in place to minimize or prevent the hazards. Monitoring practices must then be specified to evaluate the effectiveness of these preventative steps. Thorough records of this monitoring are required, as are the actions the facility will take to correct problems that might arise with these precautions in place.
Common Food Safety Challenges
Contamination is one of the biggest challenges to address in the food industry. The CDC estimates nearly 50 million Americans get sick each year because of contamination. As evidenced by the Sanitary Transportation rule that’s going into effect early next year, transportation and supply chain logistics play a major role in this area.
When food products are stored and moved within a facility, cross-contamination is another concern. Due to allergies and other food sensitivities, facilities must take the utmost care in handling different types of food. Cold chain integrity is another aspect FSMA addresses, and food operations businesses need to pay close attention. A broken security seal, exposure to outside elements or another type of breakdown in the cold chain can lead to spoilage or contamination.
Loading Dock Area Solutions
While the list of challenges is lengthy, the list of solutions is just as long. Advances in loading dock area practices and equipment help facility managers combat issues related to food safety hazards, and can help get those operations in compliance with FSMA.
Securing the supply chain — Starting at the loading dock, it’s critical to secure trailers to the facility with a vehicle restraint. By wrapping around a trailer’s rear-impact guard (RIG) or securing the trailer tire, the proper automatic vehicle restraint will keep trailers safely positioned at the facility. This is an important step in minimizing contamination concerns that might arise from debris such as dust or bugs getting into a trailer or facility, as well as from a cold chain integrity standpoint.
Some automatic restraints feature a control panel that can be integrated into building management or security systems, providing another level of security and protection against external tampering. The most advanced restraints will re-engage with the RIG (or an obstructed RIG) and re-fire if there is tampering, or the trailer attempts to pull away when in the locked position. Some models can even help secure intermodal overseas container chassis, which have become increasingly common across the food industry supply chain.
Bridging the gap from dock to trailer — Linking the gap between the loading dock floor and the trailer bed is the next step. A vertical-storing dock leveler is considered the gold standard for maintaining cold chain integrity, environmental control and security — all major points of emphasis in FSMA. This is because security seals and trailer doors can be opened and closed inside the loading dock (“drive-thru” application) instead of on the drive approach. Drive-thru operations improve cold chain integrity and enhance the security of products and processes.
Unlike a pit-style leveler, a vertical leveler (when in the stored position) allows the loading dock door to close directly on the pit floor — rather than the leveler itself — reducing energy loss by minimizing outside air infiltration. Their design makes it easy to clean or wash down the pit floor when the leveler is in the upright and stored position, too.
Properly sealing the dock perimeter — Creating an environmental barrier between the back end of the semi-trailer and the inside of the loading dock with a dock seal or shelter is imperative for food operations facilities. This connection helps companies control their environment by keeping wind, rain, dust, bugs and other contaminants outside the building, while preventing the escape of valuable energy from inside the building.
Some of the newest dock shelters have been specifically designed with the food industry in mind. In particular, some shelter designs complement the vertical-storing dock leveler to allow for drive-thru applications. An effective dock sealing system also helps prevent weather-related product damage and contamination, protecting and securing the integrity of products as they move in and out of a facility during manufacturing, processing and shipping.
Washable high-speed doors — Inside the facility, it is important to carry out contamination prevention practices with doors and walls that are easily maintained and washed. Maintaining cold chain integrity is another important factor. High-speed roll-up doors made from insulated fabrics can help separate temperatures of up to 40 degrees, as well as stand up to repeated washings. Advanced high-speed doors can withstand forklift impact accidents, which minimize maintenance and downtime associated with those types of accidents on traditionally hard, high R-value doors.
Newer upward-acting doors also incorporate a perimeter thermal air seal for added energy savings through a tighter closure. In addition to their temperature separation capabilities, the most advanced high-speed doors comply with Good Manufacturing Practices guidelines that are frequently referred to by the FDA and USDA.
High-tech products in traditionally low-tech areas — When the latest round of FSMA rules come into effect in the coming years, it’s important for facility managers to consider all of their implications and identify all potential hazards in the facility and look for solutions that will minimize them.
From employee training programs to loading dock equipment, all options must be considered to comply with these new rules. After developing a plan, consider making equipment upgrades to not only satisfy FSMA rules, but to provide the safest food possible for consumers.