Snack World - February 2013 - (Page 13)

Government Affairs FDA Publishes FSMA Proposal Agency would require companies to provide scientiﬁc validation of effective controls. BY BOB GATTY L ong-awaited proposed regulations to implement the Food Safety Modernization Act (FSMA) were issued in January by the Food and Drug Administration (FDA), and they contain specific requirements that food manufacturers and distributors provide scientific evidence demonstrating that their preventive controls are actually working to keep food safe from contamination. A detailed memorandum prepared for the Snack Food Association (SFA) by general counsel Hogan Lovells noted that while the proposed regulation “largely tracks” requirements of FSMA, the suggested requirement for scientific validation was only “implied” in the statute. However, if the rule is made effective without change, such validation will be expressly required, and food companies would need to be able to produce the scientific basis for their validation during an FDA inspection. “Food companies will need to pay particular attention to this proposed requirement,” the law firm’s memo advised. “We are glad that these regulations have finally been released by FDA,” said SFA President and CEO Jim McCarthy. “SFA will most certainly be filing comments once our analysis is complete.” The proposed rule establishes requirements for a written food safety plan, hazard analysis, preventive controls, monitoring, corrective actions, verification and associated records. Hogan Lovells said FDA “generally was responsive” to food industry requests that the proposed rule be flexible, not prescriptive, so companies could respond in a “risk-based way, consistent with the type of food and extent of controls used in a given facility.” The law firm noted that FDA did not propose specific requirements for either environmental/ product testing or supplier verification, although both are clearly included in the legislation. The agency cited high costs associated with those activities and solicited public comment regarding whether they should be made part of the final rule. “FDA includes a detailed appendix describing the agency’s views of how they would expect testing and supplier verification activities to be conducted — a ‘must read’ for all food quality directors,” the law firm’s memorandum stated. FDA cited the Global Food Safety Initiative (GFSI) framework and GFSIcertification schemes such as Safe Quality Food (SQF) 2000, www.sfa.org February 2013 Snack World 13 http://www.sfa.org

Table of Contents for the Digital Edition of Snack World - February 2013

Snack World - February 2013
Table of Contents
Letter from SFA - Busy Year Ahead
Supplier's Corner - Planning for Your Future
Calendar/News
SFA endorses Facts Up Front labeling
Government Affairs - FDA Publishes FSMA Proposal
Appeals court rules against NLRB appointments
SNAXPO 2013 - Discovering Better Business Solutions
Smithsonian Exhibit - Snacking at the Museum
New Snacks
Products & Services
Ad Index

Snack World - February 2013