FSMA Regulations from a Food Ingredient Perspective

Therefore, just because a chemical has the word food-grade used to describe it, does not mean that the chemical is going into a food. Customers of distributors frequently request food-grade chemicals due to another property that the word food-grade meets, such as the concentration or preparation. Oil and gas companies are known to request a food-grade version of a product because it has less impurities in it.

Sometimes the name of a product can be misleading, such is the case with tapioca starch, which can be used in oil and gas applications. A distributor may know exactly how its customer plans on using a chemical, but it is impossible for a distributor to know every potential use of its chemicals—and exactly how each of its hundreds of customers plan to use them. Some commodity chemicals such as caustic soda can have thousands of uses alone. Distributors frequently use a certificate of analysis to help determine how the product will ultimately be used.

Food Safety Beyond FSMA regulations—Other Food Safety Standards

Many chemical distributors have long used other quality standards such as ISO 9000, FSSC 22000, Safe Quality Food (SQF), and Global Food Safety Initiative (GFSI) to establish best practices and industry standards for their food products. NACD’s own environmental health, safety, and security program, Responsible Distribution, has elements that can be applied to food safety, including codes on handling, security, internal audits, and corrective and preventive action.

FDA has recently stated that it is interested in working with GFSI and other private standard-setting bodies to see how private standards could be used to help food facilities meet the verification requirements under the FSVP and Preventive Control rules.

What’s Next

FDA has established no less than 64 different deadlines for implementing each provision of the seven rules of FSMA. Although most of the deadlines have passed, chemical distributors are especially aware of the challenges that they face as non-traditional food facilities and stand ready to help their supply chain partners learn more about how they meet FSMA regulations.

Tuszynski is manager of regulatory affairs at the National Association of Chemical Distributors. Reach her at 571-482-3065 or [email protected].