Food Safety and Modernization Act – Impact on Agri-Food

Fizzma Compliance Mandate

The FSMA (fizzma?) regulations that were enacted over 5 years ago may only now be considered to be very “real” in terms of enforcement and compliance. These things take time and in all fairness many of the relatively new business requirements have been metered into the fabric of the industry over the course of several years.

Here is what is stated on the U.S. Food and Drug Administration (FDA) website concerning the new mandates for the agri-food chain.

“The FDA Food Safety Modernization Act (FSMA), the most sweeping reform of our food safety laws in more than 70 years, was signed into law by President Obama on January 4, 2011. It aims to ensure the U.S. food supply is safe by shifting the focus from responding to contamination to preventing it.”

That last line is interesting in that prior to 2011 it was only necessary to “respond” to a contamination incident and not “prevent” it. Reactive vs proactive. The latter seems to be a much better approach to managing our food supply system.

Document, Document, Document

The gist of the new FSMA mandates are in the recording of information about food and ingredients. First stage processors, those manufacturers who receive product directly from growers, not only need to document all processes and procedures inside the plant but also what took place outside their four walls.

Pre harvest records, for example, the application of pesticides (there are others) as well as harvest information that details the “chain of custody” from field to plant are going to be a requirement and not optional. Harvest crews, harvesters, haulers, receiving stations, plant gate entry and a lot more data are all necessary in telling the story about where, what, who, how and when of a food item before it gets turned into a can of peas, bottle of wine or package of frozen French fries.

Traceability is Trace AND Track

Recalls have traditionally focused on tracking and not tracing a product through the ag supply chain. These are two different exercises. “Track” is, essentially, looking at a specific “production lot” that may have been contaminated and determining where it went in the chain forward from problem origination to consumer. “Trace” is going backwards to the source of the problem in the first place and looking at the complete history of that product. The latter may provide a clearer picture of the problem origination.

Without both of these capabilities one really does not have a good handle on the causes of any food safety issues.

Compliance Forces Supply to Value Chain

What may occur here is that processors will require more information from growers so that they can do a better job of being proactive in their food safety initiatives. They will require more and more of the pre-harvest and post-harvest information as detailed in the FSMA guidelines.

The result may be that this data can be used in a positive way to improve processing yields for food manufacturers while at the same time enhance crop yields and quality for their suppliers. You can't optimize what you don't measure. Or, something like that.