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The Food Safety Modernization Act: An Undertaking in Progress

Ten years…that’s a long time, right?  But…not really.  The more I see 10th, 20th, or 25th anniversary releases of favorite albums or movies, the more I feel like time is slipping away…and ten years seems more like a blink.   So, when you consider the dichotomy of the slow and all-too-quick hands of time, it’s impressive how much has been accomplished, and yet how far we have to go in food safety since the Food Safety Modernization Act was enacted in early 2011.   

As much as it would be great to go with either a “yay” or “nay” as to whether it has been a success, like many pieces of major legislation, there have been both phenomenal strides as well as stagnation.  As food safety is a complex undertaking, involving waves of domestic and global political and trade relations, budgetary concerns, etc., the quality assurance of the Act itself can be a challenge at times.  As we’ll see though, overwhelmingly, FSMA has represented a tectonic shift in approaching food safety concerns, and has set the table (yes, that just happened) for increasing advances in the coming years.

The data suggests that we do have a long way to go.  The CDC succinctly summarized this in “Preliminary Incidence and Trends of Infections with Pathogens Transmitted Commonly Through Food — Foodborne Diseases Active Surveillance Network, 10 U.S. Sites, 2016–2019” stating that: “The incidence of most infections transmitted commonly through food has not declined for many years.”  Although disappointing to those invested and concerned about food safety, it is important to remember that FSMA is not a stagnant absolute, existing in a vacuum of regulatory comfort.

Instead, FSMA, like food safety itself, is a continuously evolving and changing entity.  To respond to new science and to new challenges, FSMA depends on building on foundational scientific knowledge, while adeptly adjusting to the reality of challenges of the time (COVID-19 being a great example).  Though there is a long way to go, FSMA has achieved numerous outcomes that have been important to the industry and to the march towards a safer food system.   

As Sandra Eskin, of Pew Charitable Trusts, noted in a recent food safety session at IDFA’s Dairy Forum, the reality is that while FSMA is ten years old, the compliance dates established to meet the goals of FSMA are only now a few years old. This complicates our “FSMA at 10” theme a bit, but we can surmise a great deal from both those years of buildup and those of ennactation/enforcement.   Here is a sampling of what has been accomplished by FSMA so far, as outlined by Deputy Commissioner of Food Safety Frank Yiannas in his “A Decade Later, FDA Still Working on Congressional Mandate Known as FSMA:”

  1. Food producers “must have food safety plans that include an analysis of hazards and risk-based preventive controls to minimize or prevent these hazards.”  
  2. Improved “regulatory oversight of produce and food importers.”
  3. Implemented practices to prevent food safety risks during transportation.
  4. Gained: “additional enforcement authorities, such as mandatory recall when a manufacturer fails to voluntarily pull unsafe food from the market and suspension of registration to prevent a facility from selling or distributing unsafe food.

To add to these and other advances, the FDA this year encouragingly released their “New Era of Food Safety” blueprint, laying out areas of development in the next decade of FSMA.   Along with increased traceability initiatives, meaningful use of technology, and business/retail model modernization, the blueprint centrally is built upon creating “food safety cultures.”  This means making food safety a shared goal by everyone in the plant, in the supply chain, and beyond—top down and bottom up investment–everyone is in on it.  This should further encourage that “tectonic shift” mentioned previously, fundamentally shifting existing perspectives on food safety in the industry.  The ability to shape the future of food safety and cultures of food safety will be dependent on education, industry/regulatory/academic partnership, collaboration, and advocacy on Capitol Hill, just as the shifting of views from reactionary to preventative action required these first ten years.  

As Dick Groves stated in his editorial in the Jan. 15th issue of The Cheese Reporter, “Simply put, the food safety culture matters more than regulations.”  Groves makes a good point about the centrality of food safety culture; however, perhaps it is a mixture of conceptual shifts and continued dependence on education and partnership to further spread the gospel of food safety and regulatory knowledge/standards (consider that not having an adequate hazard analysis is still one of the most commonly cited violations by the FDA) that will make the next ten years truly effective in the fight against foodborne illness. 

Ten years indeed can feel conversely like an eternity and a blink of an eye.  The first decade of FSMA has been an experiment in adaptation.  And it will continue to be so for the next ten, marrying the realities of regulatory standards with an embrace of a holistic framework of food safety and food safety culture at all levels (including establishing this at the federal level…which is crucial for funding).  Together we can continue to learn, improve, and work together towards this common goal.  Food safety is not a destination, it is a journey.  We must continue working together as an industry to reduce risk in the food supply chain, relentlessly combatting foodborne illness.  No matter how far we are able to push that boulder up the hill, there will always be further to go. Many hands make light work, though, so let’s all commit to the effort and make the next 10 years count.

Source(s):

Marler Clark. (2021, February 9). FDA’s data for 2020 shows top five violation categories at food facilities. Food Safety News. https://www.foodsafetynews.com/2021/02/fdas-data-for-2020-shows-top-five-violation-categories-at-food-facilities/?utm_source=Food%2BSafety%2BNews&utm_campaign=280373c947-RSS_EMAIL_CAMPAIGN&utm_medium=email&utm_term=0_f46cc10150-280373c947-40046447#.

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