The FDA Food Safety Modernization Act (FSMA) received a great deal of press when it was signed into law in 2011, as it represented a major shift in the focus of federal regulators from responding to food contamination to preventing it. In accordance with the legislation, the FDA has proposed a variety of new rules that are now nearing implementation.
For example, processing facilities must establish preventive control measures to reduce the risk of contamination, while science-based standards are also being established for the safe production and harvesting of fruits and vegetables. Importers will be required to verify that the food safety procedures followed by their foreign suppliers are adequate, and third-party auditors can be accredited to conduct food safety audits and to certify foreign facilities and food products.
While FSMA will close many gaps and require all industry players to follow improved food safety practices, it is impressive what companies have been able to achieve on their own initiative in recent years. Food manufacturers and their partners have driven significant change at all levels of the food supply chain, implementing rigorous measures to ensure the safety and quality of the products they provide to their customers — whether these measures are required by federal regulations or not.
An improved safety system means safe, quality food, no matter the size of manufacturer. Retailers can work with a mid-sized private label manufacturer and find the same caliber of food safety system as one implemented by the largest manufacturer in the world. It’s not about size, it has everything to do with willingness to invest time and money to stay current.
A top-notch food safety system does require upfront investment, but a food safety system found lacking impacts profits. For a manufacturer lagging in the food safety evolution, heightened food safety risk compounded with lesser food quality turns retailers to find more desirable sources.
The most recent major push for improved food safety systems began in early 2000, on the heels of several food scares, when a number of major retailers saw that declining customer confidence was affecting their bottom line. These retailers worked together to develop the Global Food Safety Initiative (GFSI) and began requiring that their suppliers comply with GFSI-certified audit schemes such as those provided by Safe Quality Food (SQF) and the British Retail Consortium (BRC), among others.
Many leading food manufacturers voluntarily chose to comply with GFSI benchmark programs long before FSMA was passed. Trailblazer Foods, for example, a private label manufacturer, is in its fourth year of SQF Level 2 certification. Proactive benchmarking speaks to a consistent commitment to maintaining an environment that ensures safe, high-quality products for customers — the ultimate goal of every reputable player in the food industry.
SQF certification, the most widely adopted GFSI benchmark scheme in the U.S., indicates that producers adhere to good manufacturing practices and use science-based methods and systems to minimize food safety risks. SQF applies to all levels of the supply chain and provides confirmation that the entire company — from its suppliers and ingredients to its processes and packaging — is compliant. The program requires annual training of all employees and emphasizes that everyone, at every level, is responsible for food safety and quality.
What does this mean in light of the upcoming FSMA implementation? How will food manufacturers and other members of the supply chain be affected? First, all players will now be held to higher food safety standards. Companies that have proactively pursued benchmarking certification will already meet the vast majority of these requirements, as the standards are similar in many respects.
For example, like SQF, FSMA will address the entire supply chain, so retailers can assure their customers that the food in their stores has been produced, processed, prepared and handled according to the highest possible safety standards along the way. FSMA, like SQF, will also require that manufacturers be able to trace every component of a finished product back to its source. However, in some respects, FSMA standards are less demanding than those imposed by industry-established certification programs. For example, FSMA will require verification only of foreign vendors, while SQF requires all vendors, both domestic and international, to complete a rigorous vendor approval process.
The United States is recognized as having the safest food system in the world, and although the federal government certainly plays an important role in keeping shortsighted companies honest, the drivers behind this remarkable accomplishment have been — and will continue to be — the individual industry players that are constantly striving to improve their practices and processes in order to provide their customers with safe, quality products.
Individual companies can still differentiate themselves in terms of internal food safety decisions. At Trailblazer Foods, for example, the quality assurance manager has the final word on all food safety decisions. No one, including the CEO, can overrule the quality assurance manager’s decision on food safety matters. In doing it this way, the quality assurance manager doesn’t have to worry about financial ramifications. It is all about what is best for the product and consumer safety.
Change may not be easy, but it is unavoidable. For companies still playing catch-up in the area of food safety, FSMA will force a change of priorities and ensure that everyone toes the line. Given the food industry’s history of proactively promoting improved safety processes, however, we can expect that companies, individually or in collaboration with other industry partners, will continue to lead the way in raising food safety standards and expectations in the future.