The Food Safety Modernization (FSMA) act will go into effect the beginning of September 2016, and these rules will impact food safety programs for the next two to three years, depending on the company size and revenue. For companies who are currently certified by a GFSI benchmarked scheme, and those who are pursuing such certification, the question arises: “Does GFSI certification satisfy any of the seven regulations or the seven pillars of FSMA regulations?”
This overview, in particular, briefly considers the ways in which the BRCGS and SQF schemes compare to 5 of the 7 Rules most relevant to food manufacturing: 3rd Party Accreditation and Certification, Preventive Controls for Human Food, Foreign Supplier Verification Programs, Mitigation Strategies to Protect Food against Adulteration, and Sanitary Transportation.
The FSMA Preventive Controls for Human Food focuses both on risk-based assessment and preventive controls, and so it has many parallels with the HACCP programs that make up the backbone of GFSI schemes. For example, all risk based process preventive controls (classically referred to as “critical control points” or “CCP’s”) are monitored, verified, and validated. In the BRCGS and SQF schemes, the risks are identified and addressed in the Food Safety Plan. More detailed comparisons for how BRCGS and SQF scheme requirements compare to FSMA have been conducted by The Acheson Group (TAG), on behalf of those schemes. The Acheson Group also participates in FSMA Fridays, an interactive webinar, that helps your facility assess FSMA implications specific to your food manufacturing operation and requirements.
Under FSMA, the US-based companies importing foreign food, ingredients, and raw materials are required to have preventive controls in place to ensure that they are safe and free from adulteration.
As the food supply chain becomes more complex, more food is crossing national boundaries and being imported to the US from around the world. The FSMA Foreign Supplier Verification Program (FSVP) and Mitigation Strategies to Protect Food against Adulteration regulations pay special attention to ensuring the safety of food originating outside the United States. Under FSMA, the US-based companies importing foreign food, ingredients, and raw materials are required to have preventive controls in place to ensure that they are safe and free from adulteration. This means that the onus is on US importers to assess food safety risk to ensure that their suppliers or processors implement appropriate preventive controls for safety of food and periodic testing to establish the standard of identity. This can be done either by conducting a second-party audit, by contracting a certified third-party auditor (such as a GFSI auditor) to conduct your audit, or by requiring that the supplier obtain third-party certification through a GFSI benchmarked scheme or that the facility could be audited by a certified auditor. Both BRCGS and SQF have requirements for a supplier approval program that more or less comply with the most of the FSVP regulations.
Finally, the Sanitary Transportation regulation focuses on mitigating the risk of contamination due to unsanitary transport practices from farm to table. For instance, the Transportation rule requires that temperature controls are maintained and monitored during the transportation of relevant commodities. The rule also requires vehicle maintenance in order to prevent contamination of food materials during transport and that carrier personnel be trained in sanitary transport practices. Both BRCGS and SQF require verification that inbound ingredients, raw materials, food and packaging materials are inspected and both schemes exceed this requirement through documented, inbound and outbound inspections. However, there is no emphasis in GFSI schemes that the third party carrier personnel be trained on concepts of sanitary transport.
As a food processor, distributor, or importer, it is important to review and compare the FSMA and GFSI benchmarked schemes for requirements and guidance documents. The FDA website is a great resource for FSMA regulations and GFSI scheme websites are useful resources for guidance documents.
