The Food Safety Modernization Act Is Everybody’s Business
By Bob Whitaker, Ph.D., Produce Marketing Association
With the U.S. Food and Drug Administration’s (FDA) release of the first of its Food Safety Modernization Act (FSMA) proposed rules on produce safety and preventive controls, we begin what will be a multiple-year process to develop final regulations. While it will be easy during this time to get lost in legislative language, metrics and details, we must always maintain sight of why we’re doing this. Food safety is about people. When our systems don’t work, people get sick.
Protecting people’s health through prevention of foodborne illness requires smart regulation and also demands a food safety-minded business culture. A food safety culture starts at the top with the person in charge and infuses every staff level and job function. It’s driven by continuous improvement, constantly in the mode of updating and reevaluating to stay ahead of food safety’s dynamic, complex and ever-changing nature. Add to these food safety culture criteria an informed understanding not only of the food safety practices for your place in the supply chain, but also of those links before and after you. That’s why it’s important to understand what’s being presented in FSMA’s proposed rules, not just for you but for each link of the supply chain.
By being knowledgeable about FSMA’s proposals and getting involved in its rulemaking process, we can help generate comments for FDA that will translate into practical regulation. Buyers can also talk with suppliers, stakeholders can talk with government officials and industry members can talk with researchers to drive a more science- and risk-based approach to food safety.
Alongside availability and price, food safety will increasingly be part of the business transaction as FSMA takes hold. Making sure you have a verifiable base line food safety program is key. For example, buyers and suppliers will be directed to consider such things as water quality and crop proximity to animals, and they’ll need data, proving that preventive controls actually work. Individually, we are responsible for every decision we make with food safety.
And we are all responsible for giving FSMA’s proposed rules the focused attention they deserve as FDA asks for our input. Regardless of your professional perspective, sitting on the sidelines at this time is not an acceptable solution. Suppliers, buyers, academics, scientists, consultants and all stakeholders who work daily on advancing food safety must participate in this regulatory process and provide feedback to the FDA. Doing so gives us a much better chance at good regulation, which is regulation that incorporates the highest levels of food safety to protect consumers in practical, efficient ways for the entire supply chain.
As the dust settles since FDA’s announcement of these initial proposed rules, what has emerged from Produce Marketing Association’s (PMA) members are questions as numerous as there are pages in the published proposals. That’s why we’ve developed resources on FSMA’s proposed rules openly available at PMA’s FSMA Resource Center. Here, anyone can access a wide range of tools and information, including detailed summaries of both the preventive controls and the produce safety proposed rules in addition to information on how to submit comments, including comment-period deadlines. As future FSMA proposals on import issues, third-party accreditation and record keeping (including traceability) are announced, we’ll continue to update the resource center with new information.
Now is a critical time to pay attention to FSMA proposals and shape this legislation by way of the public comment period, closing May 16. It’s important for stakeholders to come together to discuss what FDA has put on the table, what works and what doesn’t work, to ensure the final rules protect public health in ways that also work for our industry.
When filling their grocery carts, shoppers aren’t thinking about good agricultural practices. They’re not considering the integrity of suppliers’ Hazard Analysis or sanitary operating procedures. It’s all our jobs—each and every member of the supply chain and everyone in the business of food safety—to understand the process from field to fork and the building blocks of a food safety program necessary to safely deliver wholesome foods to shoppers. In doing so, we not only will create effective FSMA regulation, but we also will build a food safety culture across the supply chain, a culture that establishes better supply partnerships, preventive food safety programs and consumer confidence in the safety of our foods, every bite, every time.
Bob Whitaker, Ph.D., Chief Science & Technology Officer, Produce Marketing Association