After the first compliance date under FSMA (the Food Safety Modernization Act) passed this last September, the FDA began slowly rolling out their plans to regulate the industry under this landmark set of regulations. Following that, this past spring the first compliance dates passed for the Sanitary Transportation rule and the Foreign Supplier Verification Programs rule. This September another significant FSMA deadline will pass, arguably the most impactful deadline to our customer base of all the FSMA compliance dates – the compliance date for most food processors that fall under the “Preventive Controls” or “HARPC” rule under FSMA. Shortly after that, in January, many farms will pass their compliance date under the Produce Safety rule – FDA’s first venture into regulation of farms.
With all of this activity and with compliance dates quickly passing, one of the wisest things we can do in the food industry is to pause and take the time to review those guidance materials that FDA has been releasing to help the industry comply. Below we’re giving you a quick overview of what we feel is some of the most useful and important guidance FDA has released.
- Exemptions for processors under Juice HACCP, Seafood HACCP, and Low Acid Canned Foods regulations: The FDA has clarified how processors under these rules are to interpret the new regulations, and what they must do to comply.
- Produce Safety Rule Guidance: To date no guidance has been made available for this rule. FDA has published their Intent to Extend Compliance Dates for Agricultural Water. Currently, the best way for growers and purchasing agents to learn about implementing this rule is to attend the FDA-approved training which we offer.
- Foreign Supplier Verification rule: The FDA recently released some guidance for industry: What to do if covered by both FSV and Preventive Controls rules; as well as Key Facts for Importers, and More information about the FSV rule.
- Sanitary Transportation Rule Waivers: The FDA announced several waivers to the sanitary transportation rule, all of which had been communicated previously but are made clear here.
- Third Party Audits and FSMA: A great overview and clarification of how third party audits fit into the overall framework of FSMA.
- Preventive Controls Rule guidance: Although a bit older (from fall 2016) we find that food processors are still largely unaware of the very useful guidance FDA has released for this rule, including a Small Entity Compliance Guide, Draft Guidance for Industry, and clarification on how FDA Classifies Certain Activities – Harvesting? Or Processing?
We hope you find this information useful! In addition to the above, another great resource is our past newsletter articles, in which we’ve covered many of the above topics in an effort to support our customers on their path to compliance. You can also attend our various training courses or contact us for a custom training, either in person or web-based.