Using Technology to Aid the FSMA Implementation

June 19, 2013
Leavitt Partners' David Acheson attests managing the requirements of FSMA will require leveraging technology.

Anxiety over the Food Safety Modernization Act (FSMA) was reinvigorated in January when FDA released two proposed rules: one relating to produce safety, and one related to preventive controls for human foods.

Not only were the proposed rules and accompanying explanations voluminous and complicated, it was evident that FDA will be looking for industry to keep — and be prepared to provide — a lot of information. In fact, one could argue that much of FSMA is about record keeping.

About the author
David Acheson, M.D. oversees the food and import safety practice at Leavitt Partners, a consulting firm. He formerly was FDA's associate commissioner for foods.

To be perfectly blunt, if you didn't record it, you might as well not have done it. Technology can help companies perform the functions required by the FSMA — as well as prove, through documentation, that they occurred. With so much to actually do in a facility already, how much more can companies handle, especially when resources are already limited and people need to do more with less? Effectively managing the requirements of FSMA requires leveraging technology.

Information and data handling are your solutions to successfully preventing food safety problems, and this is what the FSMA is all about. There are many aspects of the newly released proposed rules related to preventive controls for human food and produce safety that can be aided by technology. Specifically, technology can be used to address:

  • Process controls -- Hazards identified as "reasonably likely to occur" need to be controlled. In many cases, processes (such as thermal processing) can be used to control hazards. The implementation of these controls and the recording of the process parameters can be done using technology.
  • Testing results -- No matter what you're testing -- incoming ingredients and raw materials, finished products, or environmental samples -- knowing what to test, how much and how often can be aided by technology. Analyzing, interpreting and acting upon test results is another area where technology can play a role.
  • Product tracking -- Where did you get something from, what did you do with it within your facility, and within your company, and where did you send it? The information needed to answer these questions is often best managed using technology to identify products, capture information associated with them and share this information with trading partners (or, if required, with regulators).

The intelligent and appropriate use of technology can not only save man-hours, but also help a company use data in ways that might not have been done before, and position companies to act on the information they are collecting.

For example, data analysis can alert you to aberrant trends. Of course, companies can manually enter data and perform analyses, but increasingly there are opportunities to automate data capture and perform real-time data analysis so that when something goes wrong, you can fix it. These might include:

  • Trending the time/temperatures of processes, to recognize when a piece of equipment is performing sub-optimally before there is a true process failure
  • Trending environmental testing results to identify recurring problem areas that might warrant further investigation
  • Linking consumer complaint data with parameters of production and product testing data to more readily identify the origin of a problem

We are continually approached by technology providers sharing their newest innovations and solutions. Many of them really are innovative, and many of them have solutions that readily fit into FSMA. Increasingly, as FDA releases proposed and final rules implementing FSMA, technology providers will respond by updating, upgrading and adapting their systems to ensure that the technology fits easily into a food safety plan, traceability system, produce growing operation or whatever aspect of FSMA companies are seeking to address.

FSMA places enough new requirements on companies, so let technology help you. Not only can technology help facilitate regulatory compliance, it can also help protect your brand.

This article originally appeared in our July 2013 issue of Food Processing magazine.

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