Notwithstanding the apprehension and anxiety that the FSMA has created for the food sector, “we’re actually seeing our clients look at the legislation as an opportunity,” reports Neuman, even though many specifics of the FSMA have yet to be released. “Clients are beginning to view audits as an opportunity to identify how to further improve their operations, rather than as something to be feared.”
Neuman senses other positive changes in the industry. “In my tenure as a food safety professional over the past 15 years, I am happy to report a progressive movement towards greater transparency in the industry and more sharing of information. The industry perspective is that food safety is not a trade secret. We’re all in this together, and the better we share and become more transparent within each company, the more we elevate and nurture the greater good of the entire food industry.”
As for advice, Neuman has a few tips for food companies who are eager to know what areas to concentrate on in their own operations.
“Employee training is one area,” she points out. “Particularly since the passage of the FSMA, it is becoming very important for companies to demonstrate that they’ve got an optimal food safety management program in place. It’s also an area that PwC looks at closely when we’re conducting a food safety assessment for a client.”
At the end of the day, documentation still reigns supreme, she says. “What’s very critical with respect to training, as well as almost all of the other elements that are regulated in the industry, is documentation. For instance, a company needs to document the training that occurred, what type of training was provided, who was trained, and how often the training was updated to reflect the most current requirements. Furthermore, training has to be provided in a very user-friendly manner. In other words, if you’ve got multiple languages being spoken in your facility, the training needs to be offered in those languages.”
According to Neuman, “Documentation is mission-critical to navigating a regulatory audit, whether we’re talking about employee training, HAACP (Hazard Analysis and Critical Control Points), sanitation practices, and so on. Because in the eyes of the auditor, if it isn’t documented; it didn’t happen.”
Expediting the process
Responding quickly to the myriad changes unfolding in the area of food safety is key, and so is a company’s ability to take the initiative to implement changes proactively, emphasizes Scott Scdoris, food and beverage director for Celsis Rapid Detection.
Scdoris explains that an important feature of the FSMA is the shift in responsibility from government to the industry, i.e. rather than government assuming a ‘gotcha’ attitude, the industry is empowered to assume more responsibility for compliance, which includes performing self-audits. This is much like C-TPAT (Customs-Trade Partnership Against Terrorism) and many other programs introduced by U.S. Customs and Border Protection (CBP) in recent years, which encourage an environment of shared compliance and collaboration between government and industry.
The approach is especially prudent today, when so many government inspection services and auditing resources are stretched to the limit.
As a result, “We’re seeing a big uptick in both self-audits as well as third-party audits,” says Scdoris, with companies such as AIB International and Randolph Associates among those that are experiencing more interest from the industry.
And, it’s not just interest from companies in the U.S., but global companies are also becoming more actively involved in food safety and audits.
Scdoris has seen “a 180 degree turnaround in several overseas markets,” he says, including China, which has been at the center of so many recall and contamination events in recent years.
“Five years ago when I would visit China, quality was not a hot button topic. A lot of companies there were shipping product while testing was ongoing. It was a ‘ship and pray’ scenario,” he says.
All that has changed, however. Not only have companies in China begun to take food safety much more seriously, global players with operations around the world are putting designated personnel in charge of food safety.
“That person’s sole responsibility is to travel from facility to facility and perform audits. We’re definitely seeing a lot more of this in the marketplace,” notes Scdoris.