IFS Blog

Four letters and a big question mark – How I got in touch with FSMA

Four letters that pack a punch: The „Food Safety Modernisation Act" – It is complex, but it is actually no rocket science – and let me explain you why:

The FDA Food Safety Modernization Act (FSMA) is indeed the most sweeping reform of US-food safety laws in more than 70 years, which was signed into law by former President Obama on January 4, 2011. It aims to ensure that U.S. food supply is safe by focussing on the prevention of contamination, instead of simply responding to it. Roughly said, all food businesses in the US, and those delivering into the US, have to comply with the FSMA rules. Such rules do not apply to businesses which are solely regulated by the USDA (farming, meat and poultry, except transportation) For the majority of businesses, deadlines have been passed already to comply with the rules. So it´s time to hurry up! 

FSMA is short for Food Safety Modernization Act, one of the most important reforms of US food safety laws.

The main regulations are the Preventative Controls for Human Food (PCHF), the Sanitary Transportation Act and the Foreign Supplier Verification Program (FSVP). Companies having an active IFS certificate are already in a good shape and just need to fill some gaps between IFS requirements and FSMA. A comparison between IFS Standards and the relevant FSMA rules can be downloaded here.

A variety of articles and webinars have been circulating through the web. Their aim: explaining how to comply with FSMA as a foreign supplier. One important fact is, that every business subject to PCHF has to have a designated Preventative Control Qualified Individual (PCQI). In order to be considered as PCQI, there are two possibilities: relevant job experience or the Food Safety Preventive Controls Alliance (FSPCA) training. The latter is also a perfect way to familiarise oneself with the PCHF rules.

So, let´s go!

Attending the PCQI training

To support companies subject to PCHF, IFS certified or not, the IFS team organized the first licensed 2 ½ day FSPCA training course in November 2017 in Berlin, hosted by lead instructor Deborah Shapos and supported by Pius Gasser, IFS respresentative for North America. A perfect team considering FSMA and IFS requirements. The training was held in English, but Pius was on standby, when translations were needed.

The training material is licensed and has to be taken as granted. Starting off with a refresher on food safety principles and US specifics, such as critical limits and allergens, step by step we learned and discussed in a team-like atmosphere how to understand this „new" risk-based approach, what is expected of the food safety plan and how to tackle compliance with PCHF when going back to work.

Lessons learnt: A matter of philosophy – the food safety plan 

A risk-based approach is already daily business for IFS certified facilities. Meanwhile, FSMA isn't the first and only risk-based program within the US food and beverage industry. We already know about numberous regulations: the HACCP according to Codex Alimentarius, the low-acid canned food regulations, HACCP for seafood and juice, USDA HACCP regulations and others.

So FSMA isn't really something totally new, it it just about a different approach to risk-based programs. FSP differentiates from HACCP plans in consideration of radiological hazards as chemical hazards, as well as hazards due to economically motivated adulteration.

Moreover, nuances of the Hazard Analysis and Critical Control Points (HACCP) system are being modified to prerequisite programs (PRPs), which are given the same level of concern as Critical Control Points (CCPs), collectively referring to all of them as preventive controls (PCs).

At the end of the day companies who are IFS certified are in a good position to comply with FSMA, they basically just need to adapt and reconsider their HACCP system and convert it to the new approach of the food safety plan.

IFS can help you with that by offering trainings, guidance and advice. 

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