As 2016 came to a close, our last FSMA Fridays session of the year with Dr. David Acheson of The Acheson Group focused on what’s ahead in 2017. For those of you who missed our December FSMA Fridays session, some interesting highlights to share about what 2017 probably has in store for us!
Big Picture Changes for Food Safety in 2017
Dr. Acheson foresees many same trends in 2016 continuing in 2017 in terms of environmental monitoring, environmental controls and recalls.
“As we look ahead to 2017, and I'm reflecting back on 2016 somewhat, we've seen a lot of very large impactful recalls as a result of environmental contaminants irrespective of whether they've actually been linked to outbreaks. Whole genome sequencing is driving us in this direction of, or driving the regulators in the Centers for Disease Control in the direction of, rather than waiting until an outbreak is well underway before we know what's going on, they're connecting the dots with just a few cases and pushing for action early, “ said Acheson.
And as part of this continuing trend, Dr. Acheson pointed out that given where the enforcement’s going, it’s environmental. “...If you don't have your environmental control program well stitched up, then I would suggest that you move ahead and get it looked at. Especially through the lens of where FDA's going today with thinking about whole genome sequencing and thinking about food companies needing to know if they have a resident strain of a pathogen in their ready-to-eat facilities, “ commented Acheson.
Compliance Dates for 2017 - Who Will be Impacted?
With FSMA rules now final, 2017 will no doubt be a busy year as compliance dates kick in. The first major compliance milestone under the FSMA Preventive Controls rule hit last September for non-small businesses.
Dr. Acheson noted that as we look towards 2017, there's a number of items to be aware of:
- The Produce Safety rule for non-small businesses is expected to come out in January
- Sanitary Transport is coming up for non-small businesses in April
- For those under the Preventive Control rule, it is important to remember there's a six month gap for your supply chain control part - Part G, that is going to hit in March
- If you're a non-small business (more than 500 people) then you're going to have to pretty much be fully compliant with all the components of the Preventive Control rule, including the supply chain part, by March
- If your supplier is a small business then that continues to push out the Preventive Control rule - of when the small businesses have to be compliant, which is the next big watershed for FSMA -- is September 2017
- Small businesses, small manufacturers, processors, packers, and holders will need to be compliant with FSMA by September 2017
What Should Food Companies be Most Worried About Today and Going Forward?
Environmental monitoring, control programs, supply chain risk control programs, and having a food safety plan will continue to be critical key trends in 2017.
According to Dr. Acheson, “For the environment, the whole genome sequencing...the CDC is pushing it, FDA is pushing it. Increasingly FSIS is pushing it. That's where I see this going first and foremost. That's what I'm most concerned about for food companies.”
Dr. Acheson elaborated on this by saying, “...when we see a case with a specific whole-genome pattern, a human case, it is obviously being entered into the data banks. If there's any indicators that there's a problem with a food or a facility, the FDA will be in there with their bag of swabs. If you flip that around and you say, ‘Well, we've got a human illness, and it's linking back to an isolate we found in your plant a year ago,’ the FDA is saying, ‘Well, you need the epidemiology to link it together,’ before they take any actions.”
In addition, companies should be prepared to answer any questions in regards to supply chain risk controls and be able to show and validate their food safety plans.
“Even if, frankly, (your food safety plan) is still a work-in-progress ... you don't have all the validations done, and you don't have all the bells and whistles in there, do be ready to be able to answer that question around - show me your food safety plans,” said Dr. Acheson.
With many significant recalls in 2016, companies need to be prepared and must have a recall plan ready as it is now a requirement.
“Remind people, if you've got a food that you've determined requires a preventive control, then you need to have a documented approach to be able to recall that under FSMA, ” said Dr. Acheson.
And There’s More!
Access the full session recording to hear more of Dr. Acheson’s perspective on the road ahead in 2017 including what we can expect from FDA with regard to FSMA enforcement.
Need help ensuring FSMA Compliance?
The Tag team can help you identify gaps and update your food safety and recall plans. For more information visit www.achesongroup.com.
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FSMA Fridays in 2017!
Be sure to save the date for our first FSMA Fridays of the New Year- Friday, January 27. We are expanding our FSMA Fridays series – more details to come! Not part of FSMA Fridays? What are you waiting for - sign up at https://safetychain.com/resources/fsma-fridays/.
Here’s to a healthy and productive 2017!