Do it now
A good way to prepare for F.S.M.A. is to get your H.A.C.C.P. plan and cGMPs up to date. Then work to fit them to F.S.M.A. regulations.
“One of the first steps is hazard analysis,” Dr. Brackett said. “This may be the most comprehensive and complicated step for bakers, indeed, for all food manufacturers. You may need help from experts, university specialists and others. The results of this analysis will drive the rest of the process.”
Some elements of F.S.M.A. are enforceable now, specifically registering of food facilities and establishing a food safety plan. Because two rules won’t be final until later this year, their deadlines for compliance are also delayed, and different timelines affect companies of various sizes. “The first step should be to conduct an analysis of requirements for developing a F.S.M.A. compliance plan,” Mr. Bremer said.
Rules involving preventive controls for human foods, the foreign supplier verification program and food defense should be the first F.S.M.A. programs to address, according to Mr. Steed.
“Set up a transition team to develop and implement the plan,” he said. “Educate and train personnel at all levels, starting with the P.C.Q.I. Understand that plant managers will be held accountable.”
Don’t just write down your H.A.R.C.P. program; run it, and start documenting the results.
“Implement and review your preventive control records to ensure that they accurately portray the sanitary conditions at your plant and any improvements to those programs,” Mr. Hugo said.
The success of preventive controls will be judged by the authenticity of the facility’s records and its ability to demonstrate that improvements are being made.
“I’ve been to many food facilities in 25 years,” Mr. Payne said, “but the one I will always remember is the one that required me to take a half-hour class in food safety — and complete a test of my knowledge — before admitting me into the plant. That’s quite a proactive approach on the part of the company. That’s the type of thing companies should do. You can’t get complacent.”
And as a word of caution for all, Dr. Brackett advised, “Take it seriously.”
