Avoid These Common Mistakes When Preparing a FSMA-Compliant Food Safety Plan

Since the Food Safety and Modernization Act (FSMA) went into effect in 2011, U.S. companies have had to take their food safety practices to a new level. The law introduced substantial changes, such as a stronger focus on prevention, new hazards to consider (radiological, allergen control, and economically motivated adulteration), more transparency and accountability, and a closer inspection of the supply chain.

Adapting to these provisions means new challenges for food businesses, especially when it comes to preparing the food safety plan, the written document or set of documents in which companies must explain how they prevent food safety incidents from happening and how they’ll manage an emergency if one does happen.

Prevention’s Biggest Enemy: Complacency

The authors of the FSMA greatly reduced the application of Hazard Analysis and Critical Control Points (HACCP) in favor of a framework called Hazard Analysis Risk-Based Preventive Controls (HARPC). Compared to HACCP, HARPC is more proactive, less reactive, and has a stronger focus on risk-based prevention. For food companies, one of the practical consequences of this shift is that steps and procedures that were part of HACCP’s Prerequisite Programs are mandatory in HARPC.

Although this is a significant change, according to Nancy Scharlach, president and chief technical director at FSMA International, many operators tend to think that preventive controls are just HACCP with a different name. “A lot of companies are too complacent, still in the mindset that they only have to make a few tweaks to their HACCP plan in order to be FSMA compliant,” she says. “In fact, we’ve grown beyond HACCP. The FDA felt that it didn’t cover all of the critical recall subject matters like allergens, environmental pathogens on ready-to-eat food, and food fraud from within the supply chain.”

The other risk of a complacent attitude is to have a false sense of security. “When companies use their HACCP plan as a reference to build their FSMA food safety plan, sometimes they don’t carry risks over,” says Mathew Suri, president of Essential Food Safety Consulting. “If they identified a hazard in their HACCP plan but never experienced a problem with that hazard, they just might not include it in their risk assessment, when in fact they still need to keep track of it as a potential hazard.”

Another common mistake is not being specific enough. “Many food safety plans that we review worldwide are too generic,” says Scharlach. “You’ll see a hazard analysis that simply says: ‘biological hazard,’ ‘pathogens,’ or ‘allergens.’ But you need to know which allergens or pathogens are unique to your production line.”

For Brian Perry, senior vice president of food safety and quality at TreeHouse Foods, a manufacturer and distributor of private-label packaged foods and beverages, conducting a correct hazard analysis was one of the main challenges to making his company’s food safety plan FSMA compliant. “One of the things that we worked to improve upon across the board was making sure that we’re looking at all the inputs from the supply chain and at our risk assessment in a broad sense. We tend to focus very much on microbiological hazards because of the public health elements, but we can’t ignore radiological, chemical, and physical hazards.”

Finding the Right Resources

What complicates things further for food companies is that they don’t always know where to find resources and guidance to put together a food safety plan, making the mistake of falling back into what they already know.

According to Perry, companies shouldn’t be insular in their risk assessment. They should actively seek expert opinions and use all the materials provided by the FDA and other food safety institutions.