Recap of July's Special Extended FSMA Fridays Session on What Being FSMA Compliant Really Means [Recap Part 2 of 3]
FSMA a cultural shift? You bet. It makes sense and up until now, I have not heard that perspective conveyed as eloquently and succinctly as Dr. Acheson did during SafetyChain’s extended FSMA Fridays July session where we explored, “What Being FSMA Compliant Means to You".
We’ve been hosting these monthly informative sessions for 3+ years with Dr. David Acheson and The Acheson (TAG) team, and have always focused on very tactical FSMA-related issues and analysis of the latest FDA updates on all things FSMA. This session took a quick turn from tactical to philosophical, as Dr. Acheson distilled his thoughts, and help cut through the hype of what being FSMA compliant really means.
Dr. Acheson couldn’t have said it better: “I think if we look at our challenges for FSMA implementation, it is more one of recognizing that it is not a project. I think if we're approaching FSMA compliance as this project with a beginning, a middle, and an end and we can check project complete, we're missing the point.”
“FSMA is about a culture shift. It is about moving philosophy, thinking, strategy in food companies from reactive to preventive. It is about looking at risk through a different lens. I think what we're all focused on… is, have I got my food safety plan? Is it where it needs to be?”
“.. what FSMA is trying to achieve is a philosophical shift to say, yes, we need to be looking at risk, across the whole enterprise, and those high risk items that we deem need to be controlled for public health reasons. They need to be controlled and how we're going to do that? (What’s our plan?) That's the project part. That's the exercise. Right now that's 90 percent of the focus.”
Of course with FSMA compliance dates upon us, the focus has to be tactical and how can it not be? But taking a step back and looking at the forest amongst the trees, Dr. Acheson continues:
“Twelve months from now, for large businesses who have been compliant for a year, that focus needs to switch .. 90 percent of the effort .. put on the verification that the program is working. The maintenance of the systems, the ability to document that when you've had a situation you've had corrective action and then you've gone back and adjusted your food safety plan if you need to.”
And then comes the hard part. The shift that is imperative for FSMA compliance to work - ensuring ongoing “program” maintenance. A concept that is not foreign to anyone in this industry but somehow as a point of discussion has not been the focus when it comes to FSMA.
Acheson continues, “Right now .. we're on 90 percent project focus, let's get our food safety plan built. My belief is, arguably, that's the easy part. What's going to be difficult is maintaining this level of focus moving forward into 2017, 2018 and beyond as the culture of the company needs to understand this isn't just a project with a project cost, this is a culture shift. Getting the C-suite to recognize that is going to be a key part of success.”
“Remember that as we evolve in 2017, 2018 and beyond the FDA inspector is going to become better and better and better at this. They are going to shift from, show me your food safety plan to show me how your food safety plan is continuing to operate on a day-to-day, hour-by-hour basis, and that your preventive control qualified individual is indeed monitoring the programs, looking for the points where it's deviated, making those corrective actions, documenting them. It's shifting truly from the project to the living, ongoing culture shift, which is what FSMA is all about.”
Thank you Dr. Acheson for that perspective, culture shift indeed!
And there was quite a bit more shared.. be on the lookout for the next and final recap of this informative session: FSMA Compliance – What it distills down to and steps for getting prepared.
Missed part 1 of this recap? Here you go: What Being FSMA Compliant Means to You
Not a member yet of our FSMA Fridays monthly series? What are you waiting for? visit: www.FSMAFridays.com