Don’t Get Flattened by the FSMA Steamroller
By Scott Grzesiak
For food and beverage company executives and directors of quality, the looming demands of the Food Safety Modernization Act (FSMA) are less like an ambush and more like waiting to get run over by a steamroller. The threat seems a long way off, but if you don’t prepare, you’ll get flattened.
The clock is ticking down on 2018, when food companies of all sizes must comply with FSMA mandates. Quality control experts may know what’s needed to be compliant—and may have even begun taking steps toward implementation—but are probably not getting the needed buy-in and support from other functional areas of the business to make necessary changes and meet deadline.
So how can you take ownership of this process and kick it into gear?
Start With a Plan
FSMA compliance centers on the development of a food safety plan, which will help steer the company through the process of meeting the new regulations. At the heart of this plan are five core components:
- A written hazard analysis to identify any biological, chemical or physical element that could cause illness or injury;
- Written preventive controls to address the identified hazards, which should address production processes, material handling processes, equipment and facility sanitation, allergen cross-contamination and the entire supply chain;
- Procedures for monitoring, taking corrective action and verifying that the preventative controls put in place are working;
- A recall plan so the company can act quickly to minimize the consumer impact; and
- Records to document that the plan has been fully implemented.
On Your Mark, Get Set…
Although the requirements of the food safety plan can seem overwhelming, there are some basic steps you can take to meet the deadline:
- Get buy-in from the C-suite. FSMA compliance isn’t just a problem for the quality department to solve. Because it affects the whole organization, FSMA compliance must be a company-wide initiative. Getting executive-level support for the complexities involved is an important first step. This means you will have to explain both the magnitude of the effort and the consequences of noncompliance.
- Get organized. Compile all existing food safety policies and procedures, and then conduct an audit to determine the gaps in your plan. Gaps can crop up when your documentation hasn’t kept current with changes in a production process, after the installation of new equipment, or when expanded product lines include new ingredients that are allergens.
- Gather your team. Recruit representatives from each functional area of your company who are respected by their peers as knowledgeable in their individual areas and who have the support of their immediate supervisors. Select people to whom you’ll feel comfortable delegating tasks.
- Start with the hazard analysis. This is the most difficult but important step in developing a comprehensive, effective food safety plan. Don’t assume your existing hazard analysis and Critical Control Points plan covers all hazards. You might have to expand its reach to cover new points of emphasis or new scientific research, such as the best ways to destroy a specific pathogen. Additional modifications may be required when a hazard is generically referenced (e.g., “pathogens” instead of the actual organism of concern), making it difficult or impossible to define the controls needed to manage it.
- Focus on the biggest risks first. Begin prioritizing the steps you need to take to close the identified gaps. This process hinges on a comprehensive risk assessment, balancing the potential impact to consumers versus the probability of occurrence. You should address the biggest risks first. For example, if your food safety plan didn’t include steps to deal with cross-contamination from allergens like sesame, sunflower or poppy seeds—exposure to which can be dangerous for many people—addressing this should be top priority. A caveat: It may be tempting to grab the “low-hanging fruit” by fixing those gaps that are easiest to close, but this approach will leave you exposed to the big risks for a longer period, increasing potential for a recall.
- Have a plan. Becoming compliant with FSMA will involve dozens, potentially hundreds, of individual but interrelated tasks. Create a detailed implementation plan that clearly delineates who is responsible for every task, then charge someone with leading the program to make sure you’re staying on track.
- Make the change—and make it stick. Employ sound change management tactics (cross-functional involvement, regular communication, training for all affected, etc.) to ensure sustainable, consistent adherence to the new processes that will guarantee FSMA compliance—not only on the first day they’re rolled out, but every day thereafter. This requires organizational support and individual discipline; failing to follow even one small element of the plan can lead to severe consequences for the consumer.
FSMA compliance can be a challenge, but following these steps will help you get your organization out of the way before the steamroller hits.
Scott Grzesiak is managing director at Integrated Project Management Inc. Reach him at 630-789-8600, or visit IPMCINC.com.