There’s a reason Santa and Mom always use checklists. They work. It’s no different in the realm of food safety. Make a list, check it twice, have a backup plan. In many ways, that’s what the Food Safety Modernization Act (FSMA) and its accompanying rules are all about — preventing problems through a systematic, science-based approach. Food businesses along the supply chain, from the fields all the way to the grocery store shelves, must be in compliance with various aspects to the FSMA rules beginning this fall. A phase-in approach gives medium-sized and smaller operations more time. Signed into law in January 2011, the FSMA gives the Food and Drug Administration new tools in the quest for safer food through preventive efforts, rather than the reactive approach that had been the norm. Two key areas of the law include:
- Mandated inspection frequency: The FSMA establishes a mandated inspection frequency, based on risk, for food facilities. All high-risk domestic facilities had to be inspected within five years of enactment of FSMA and no less than every three years thereafter.
- Records access: FDA will have access to records, including industry food safety plans and the records firms will be required to keep documenting implementation of their plans.
For decades food businesses have faced government inspections from local, state and federal entities, spurring last-minute checklists for tidying up operations. In more recent times, third-party food safety audits, boosted by requirements from retailers and ingredient buyers, resulted in similar spot preparations for spot checks. Such inspections and audits provided a snapshot of an operation’s food safety status on a given day but did little to ensure the routine and repeated execution of food safety procedures. Part of the rational behind the FSMA’s accompanying rules, as described by FDA Deputy Administrator Mike Taylor is to help food producers, handlers and retailers develop and consistently apply policies and protocols so those snapshots of food safety become more like streaming video — uninterrupted processes and procedures that are part of every employee’s work every day. Many academic institutions, extension offices, industry associations and quasi-governmental organizations and software providers have developed materials to assist food businesses in the assessment and development of food safety plans and the checklists that make it possible to execute those plans. A common denominator in the materials, regardless of the source, is the reminder that checklists are a crucial part of any food safety plan, but they should not be confused with the plan itself. Discussions of FSMA-required food safety plans have been dominating food industry conferences and conventions for the past five years and a new event this spring was no different. At the inaugural Restaurant Franchising & Innovation Summit in Dallas in March representatives of large and small chains shared ideas, concerns and practices about food safety plans and checklists. The plight of Chipotle Mexican Grill in recent months has provided an ongoing reminder to others in the restaurant arena about the impact a food safety failure can have. Jeff Linville, president and CEO of Taco John’s International, described a foodborne illness outbreak as a “brand killer” and described how high-tech solutions are part of the Taco John’s food safety plan. “It’s unbelievably important to keep your brand safe. With technology, within in a very short amount of time we can find out where it (a contaminated ingredient) came from and shut it down. We can have a team activated in two to three minutes,” Linville said during a presentation at the summit. Fresh produce is one category of food that requires special attention through the entire supply chain because of growing/harvesting methods and the fact that it is frequently consumed raw. Without cooking to provide a kill step for pathogens, produce is considered high-risk in terms of food safety. Chris McNutt, vice president of brand programs for CSCS, the corporation behind Applebee’s restaurants, said the chain has a list of high-risk produce items in its food safety plan and special procedures in place for minimizing the potential for problems. (To sign up for a free subscription to Food Safety News, click here.)