The Highest Calling

These new FDA requirements go into effect in July. Fortunately, affected food companies can learn a great deal from the lessons of the past decade. A few notable observations can particularly help all companies prepare today for the changes the FDA will soon begin enforcing.

First, food companies must understand that if their food products are contaminated with pathogens when they leave the company’s control, those contaminants will likely be found. This is because more and more food companies are sampling incoming raw materials and finished products before using or selling them. Even if such contamination is not detected through downstream testing, foodborne illness and outbreak surveillance has become so robust that, if a food product causes a foodborne illness or outbreak, investigators will be able to trace it back to the offending company. All companies must recognize that if contaminants exist, they will, through industry testing or national outbreak tracking, be found.

Second, for each of the reasons outlined above, companies also need to understand that the best time and place to prevent or control pathogens is before the product leaves a company’s control. Thus, all food companies need to embrace the new HACCP requirements, viewing them not as another regulatory burden but as an “insurance policy” designed to protect the company and its customers.

Third, when working to develop an effective HACCP plan, companies should strive to keep it simple. If the plan is too complicated, it may become impossible to manage effectively. Moreover, because a company’s HACCP plan will become, in essence, an extension of the federal regulations under which the company will be judged, the amount of federal intrusion and second-guessing will be minimized if the plan is kept simple.

This simply means each company should identify those food safety risks it fears most and then develop science-based controls to address each risk. Whether this involves incoming raw material sampling, temperature management, or other controls will ultimately depend upon the specific products a company produces. With that said, each company should consider hiring a food safety lawyer to review its HACCP plan, as well as incoming raw material specifications and finished product guarantees, to make sure every risk is not only identified but also adequately controlled.

Finally, FSMA also creates the opportunity to shift some of the burden upstream. While there may be many risks a company faces in its own operations, some of those can be better managed by suppliers. In this regard, companies can require their suppliers to identify those risks that concern them most, then require that the supplying companies adopt protocols to control each one. Here too, companies can keep their food safety plans as simple as possible, while passing certain obligations to upstream suppliers.

In the end, as long as a company’s HACCP plan anticipates and controls the concerns it fears most, either internally or at the supplier level, it can rest easy knowing that its customers, the company, and the nation it feeds will be protected.

Where We’re Going

If the past 100 years provides any lesson, the next 100 years will bring even greater change. As our food supply continues to mature globally and more food products are imported, the challenges we face at home will grow exponentially. And, with the global food supply continuing to expand as it has at home for the past 100 years, we will be confronted with more challenges and—sometimes—more risk.

But with each new challenge comes new opportunity. By being proactive and embracing HACCP as a food safety solution rather than a regulatory burden, we can immunize ourselves from those risks.