What You Need to Know About the Food Safety Modernization Act (FSMA)

FSMA 204(d): Food Traceability Requirements

FSMA Section 204(d) requires the FDA to establish traceability requirements for high-risk foods, including those on the FDA’s Food Traceability List (FTL). This means that food processors, suppliers, manufacturers, distributors, packers, and retailers must collect specific data points to track the movement of these products throughout the supply chain. The goal is to enable rapid identification and removal of potentially contaminated food from the market, reducing foodborne illnesses.

Under FSMA 204(d), importers must also develop a written plan for ensuring the food safety of imported products. This plan must include a Foreign Supplier Verification Program (FSVP), which verifies that the food they import meets US safety standards.

Requirements of FSMA

The FSMA has seven key rules that transform the legislation into actionable steps across every stage of the global supply chain. These rules aim to minimize contamination risks and streamline the implementation of necessary changes.

Below are the rules of FSMA:

1. Enforce Preventive Controls for Human Food: Facilities handling human food must create and maintain a food safety plan that identifies potential food safety hazards and implements preventive measures. This rule helps restaurants maintain compliance and protect consumers from contamination risks.
2. Apply Preventive Controls for Animal Food: Facilities that produce or handle animal food must follow similar protocols by implementing hazard analysis and control plans. It ensures the safety of animal-derived products used in restaurants and helps prevent contamination from the source.
3. Comply with Produce Safety Standards: This rule sets standards for the safe growing, harvesting, and handling of fresh produce. It reduces the risk of contamination before the food reaches your kitchen, giving your team more control over food safety from farm to fork.
4. Ensure Foreign Suppliers Meet FDA Standards: Importers must verify that their international suppliers follow US food safety regulations. It helps large restaurant chains confidently source ingredients globally while minimizing compliance risks.
5. Use Accredited Third-Party Certification Bodies: Third-party auditors can perform voluntary audits to ensure food facilities meet FDA standards. Using certified bodies streamlines compliance and prepares businesses for regulatory inspections.
6. Develop a Food Defense Plan: Restaurants and food facilities must assess risks of intentional adulteration and document strategies to reduce those threats. A solid food defense plan helps prevent sabotage and ensures consumer trust in high-traffic locations.
7. Meet Sanitary Transportation Requirements: Companies transporting food must ensure proper sanitation during loading, unloading, and transit. This rule minimizes cross-contamination risks during distribution and supports safe food delivery from suppliers to stores.

Best Practices to Comply With FMSA

Now that we have discussed the key requirements of FSMA let’s dive into some best practices that companies can follow to comply with FSMA regulations.

Conduct Thorough Food Safety Audits

• Internal Audits: Regularly perform internal audits to identify gaps in compliance and ensure processes meet regulatory standards. Use Good Manufacturing Practices (GMP) audit checklists to guide these audits.
• External Audits: Consider hiring external auditors for a more objective assessment.

Implement Preventive Controls

• Hazard Analysis: Conduct thorough hazard analyses to identify potential risks in your food production processes.
• Risk-Based Preventive Controls: Develop and implement controls to mitigate identified hazards, including biological, chemical, and physical risks.

Develop a Comprehensive Food Safety Plan

• Documentation: Sodexo leverages technology to digitize and streamline its food safety regulation records.
• Supply Chain Management: Ensure suppliers adhere to strict food safety standards and maintain necessary documentation.

Implement a Quality Management System (QMS)

• Centralized Record Keeping: A QMS can streamline compliance documentation, track test results, and manage supplier documents.
• Employee Training: Train all employees on FSMA requirements and preventive controls.

Establish Monitoring and Verification Procedures

• Regular Monitoring: Implement procedures to regularly monitor the effectiveness of your food safety plan.
• Verification Records: Maintain detailed records of monitoring activities and verification processes.

Develop a Robust Recall Plan

• Preparedness: Have a comprehensive recall strategy in place to quickly respond to potential food safety incidents.
• Communication: Ensure clear communication channels for recall notifications and remediation efforts.

Implement Traceability Systems

• Supply Chain Visibility: Develop systems to track products and materials throughout the supply chain.
• Lot Tracking: Maintain records of product lots, ingredients, and shelf life to facilitate quick recalls if needed.

Stay Updated on Regulatory Changes

• Regulatory Awareness: Continuously monitor updates to FSMA regulations and adjust practices accordingly.
• Industry Collaboration: Engage with industry peers and regulatory bodies to stay informed about best practices.