Food Safety
search
Ask Food Safety AI
cart
facebook twitter linkedin instagram youtube
  • Sign In
  • Create Account
  • Sign Out
  • My Account
Food Safety
  • NEWS
    • Latest News
    • Sponsor Insights
    • Sponsored White Papers
  • PRODUCTS
  • TOPICS
    • Contamination Control
    • Food Types
    • Management
    • Process Control
    • Regulatory
    • Sanitation
    • Supply Chain
    • Testing and Analysis
  • PODCAST
  • EXCLUSIVES
    • Food Safety Five Newsreel
    • eBooks
    • FSM Distinguished Service Award
    • Interactive Product Spotlights
    • Videos
  • BUYER'S GUIDE
  • MORE
    • NEWSLETTERS >
      • Archive Issues
      • Subscribe to eNews
    • Store
    • ASK FSM AI
  • WEBINARS
  • FOOD SAFETY SUMMIT
  • EMAG
    • eMagazine
    • Archive Issues
    • Editorial Advisory Board
    • Contact
    • Advertise
  • SIGN UP!
RegulatoryFDAFSMA

FSMA: The Recipe for Food Safety Success

October 6, 2015

Hailed by the U.S. Food and Drug Administration (FDA) as the most sweeping reform of U.S. food safety law in more than 70 years, the Food Safety Modernization Act (FSMA) was enacted in 2011—and surged to the forefront of food industry discussion and study—against a backdrop of ongoing food-related illnesses that each year sickened tens of millions and caused several thousand deaths. FDA touted that FSMA would fundamentally shift the food safety paradigm—from reacting to adulterated food after it reached the marketplace in a time-constrained effort to minimize the harm such products might cause consumers to preventing contaminated food products from reaching consumers in the first place.

The final version of the complex regulations that form FSMA’s core have been long in the making. Last month, FDA issued the first of seven final rules—the “Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventive Controls for Human Food.” This preventive controls for human food rule is largely the same as the initial version of the rule proposed by the FDA nearly three years ago. In short, covered facilities should design and implement a written food safety plan that includes:

•    Analysis of known or reasonably foreseeable and hazards

•    Measures to prevent or minimize the likelihood the identified hazards will occur, including process, food allergen, sanitation and supply-chain controls

•    Oversight and management of preventive controls to make sure that they are carried out

•    Verification to make sure that preventive controls are up-to-date and effective

•    Corrective action procedures to correct both isolated production problems and more systemic preventive control flaws

•    Record review and record-keeping protocols

•    A recall plan

Of course, even a well-thought-out food safety plan is doomed to failure if it is poorly implemented and employees are unaware of its provisions or are inadequately trained to carry out its protocols. The rule therefore requires that personnel have the food safety education, training or experience appropriate for their jobs, the food product at issue and the facility in which the food product is manufactured, processed, packed or held and that the facility maintain training records—a significant change from the rule as originally proposed.

The deadline for compliance with the preventive controls for human food rule, which ranges from 1–3 years, depends on the size of the food business. Large companies must comply within 1 year—September 17, 2016—of the final rule’s publication. Medium and small-sized companies have 2 and 3 years, respectively, in which to comply.

Compliance with the preventive controls for human food rule should pose little hardship for many companies. The rule encompasses best practices the industry has long discussed and which many food manufacturers, processors and others in the food supply chain have utilized for years in an effort to reduce the risk of producing adulterated food products. Nevertheless, the food safety headlines remain replete with product recalls and foodborne illness outbreaks that involve food companies with existing, and often sophisticated, food safety plans. Poultry, beef, milk, spinach, cantaloupes, peanut butter, spices and even ice cream are just a few of the types of food products that have been subject to recent recalls for possible pathogen contamination. Many more products are recalled on a daily basis due to undeclared allergens, possible misbranding and other potential adulterations.

The ongoing bevy of recalls and outbreaks begs the question whether a company’s well-crafted food safety plan is sufficient to protect consumers, safeguard hard-earned company brands and business, and stem the tide of the types of food safety-related complications that were the catalyst for FSMA. Even when coupled with other safeguards that the remaining core FSMA rules will embody, empirical evidence and common sense both suggest that the answer is no.

What, then, are the missing ingredients for food safety success? There are at least two: proactive, realistic, and transparent assessment and management of internal food company operations and external supply relationships, domestic and foreign. Food companies must treat FSMA and their food safety plans as core components of their daily operations, and not as a static agreement or set of rules to be shoved in a filing cabinet and shown the light of day only after a food safety-complication arises. In short, food companies must:

•    Prepare for FSMA—including which regulations apply to a company’s internal operations and external supply partners

•    Adequately train personnel

•    Implement transparent food safety preventive measures, internally and externally

•    Build sufficient flexibility into their plans and relationships to allow for change with minimal disruption where needed to promote food safety

•    Thoughtfully negotiate and precisely draft supply and vendor agreements that meet the company’s food safety related needs

•    Vigilantly manage and oversee internal operations and external relationships

•    Continually assess, and when needed, alter operations and relationships

Consumer food purchases increasingly are being driven by concerns about traceable foods and transparent operations—from where a product and its ingredients hail and how it was produced. With proper training and planning, careful contracting and oversight, food companies can hit on the recipe for successfully meeting consumer demands, growing their brands and avoiding being the subject of the next recall or illness outbreak.

John T. Shapiro, Esq., is partner and member of the Food Industry Team at Freeborn & Peters LLP (Chicago).

 


Author(s): John T. Shapiro, Esq.

Looking for quick answers on food safety topics?
Try Ask FSM, our new smart AI search tool.
Ask FSM →

Share This Story

Recommended Content

JOIN TODAY
to unlock your recommendations.

Already have an account? Sign In

  • people holding baby chicks

    Serovar Differences Matter: Utility of Deep Serotyping in Broiler Production and Processing

    This article discusses the significance of Salmonella in...
    Methods
    By: Nikki Shariat Ph.D.
  • woman washing hands

    Building a Culture of Hygiene in the Food Processing Plant

    Everyone entering a food processing facility needs to...
    Training
    By: Richard F. Stier, M.S.
  • graphical representation of earth over dirt

    Climate Change and Emerging Risks to Food Safety: Building Climate Resilience

    This article examines the multifaceted threats to food...
    Contamination Control
    By: Maria Cristina Tirado Ph.D., D.V.M. and Shamini Albert Raj M.A.
Manage My Account
  • eMagazine Subscription
  • Subscribe to Newsletters
  • Manage My Preferences
  • Website Registration
  • Subscription Customer Service

More Videos

Sponsored Content

Sponsored Content is a special paid section where industry companies provide high quality, objective, non-commercial content around topics of interest to the Food Safety Magazine audience. All Sponsored Content is supplied by the advertising company and any opinions expressed in this article are those of the author and not necessarily reflect the views of Food Safety Magazine or its parent company, BNP Media. Interested in participating in our Sponsored Content section? Contact your local rep!

close
  • Darkling Beetle
    Sponsored byElanco Animal Health

    Integrated Pest Management: Protecting Poultry Operations as Seasons Change

  • NEVIFIT 3 Compartment BPA-FREE
    Sponsored byCorbion

    The Risks of Ready-to-Eat: Five Ways to Protect Today's Prepared Meals

  • a group of workers in a food production facility
    Sponsored bySkillUp by Registrar Corp

    How to Build a Better Training Program: Data and Insights from the Global Food Safety Training Survey

Popular Stories

half full baby bottle next to rubber duckie on white surface

Organic Infant Formulas Caused Back-to-Back Botulism Outbreaks—What Gives?

alfalfa sprouted seeds

Salmonella-Tainted Alfalfa Sprouts Sicken 109 People in 11 European Countries, One Death Reported

father feeding baby

Novel C. Botulinum Test for Infant Formula Developed After ByHeart Study Reveals Industry Standard Falls Short

building a skilled workforce ebook

Events

June 30, 2026

FSMA 204 in Practice: Building a Traceability-Ready Operation

Live: June 30, 2026 at 11:00 am EDT: Attend this webinar to learn how food businesses can move from fragmented records toward a more reliable approach for recall response, FDA requests, and supply chain visibility.

July 21, 2026

Using AI Responsibly in Food Safety Management Systems

Live: July 21, 2026 at 2:00 pm EDT: This webinar will provide participants with guidance on how to effectively use generative artificial intelligence (AI) tools to develop key components of a food safety management system (FSMS).

August 6, 2026

Beyond Sanitation: Understanding the Hidden System Conditions That Allow Pathogens to Persist

Live: August 6, 2026 at 2:00 pm EDT: Attend this webinar to learn strategies for strengthening environmental control programs through a layered approach to pathogen management.

View All

Products

Global Food Safety Microbial Interventions and Molecular Advancements

Global Food Safety Microbial Interventions and Molecular Advancements

See More Products

Related Articles

  • Traceability Is Not a Substitute for Transparency in the Recipe for Food Company Success

    See More
  • Ingredient Challenge Studies: A Recipe for Assuring Food Safety

    See More
  • helen 3A

    Achieve food safety success

    See More

Related Products

See More Products
  • 1118396308.jpg

    High Throughput Analysis for Food Safety

  • 1119053595.jpg

    Food Safety for the 21st Century: Managing HACCP and Food Safety throughout the Global Supply Chain, 2E

  • 1119258073.jpg

    FSMA and Food Safety Systems: Understanding and Implementing the Rules

See More Products

Related Directories

  • BD Food Safety Consultants LLC

    We are a Food Safety Training and Consulting firm located in Naperville, IL. Our primary goal is to provide with effective training and consulting solutions for Food Manufacturing and Distributing companies. Our training services include the following: FSPCA PCQI classes, IAVA Courses, IHA Accredited HACCP classes, FSVP Courses and Internal Auditor Training classes. We also offer Learning Management System for food manufacturing industry.
  • Spoiler Alert Food Safety

    Spoiler Alert! Food Safety is the premier cloud based digital food safety platform for iOS. This powerful yet simple to app allows you to; track food rotation, generate easy to read smart labels, track product life cycle and alert all of your mobile devices along the way. Our exclusive eco-friendly wash away labels rinse safely down the drain. Starting at just $9.99/mo. Start your 30 day FREE trial today. https://www.spoileralertfoodsafety.com Download in the App Store - Spoiler Alert Food Safety Developed in the U.S.A. by restaurant professionals, for restaurant professionals.
  • Food Safety News

    Food Safety News advances public health by delivering timely, accurate, and comprehensive coverage of foodborne illness outbreaks, recalls, and regulatory developments that impact the safety of our global food supply.
×

Never miss the latest news and trends driving the food safety industry

Newsletters | Website | eMagazine

JOIN TODAY!
  • RESOURCES
    • Advertise
    • Contact Us
    • Directories
    • Store
    • Want More
  • SIGN UP TODAY
    • Create Account
    • eMagazine
    • Newsletters
    • Customer Service
    • Manage Preferences
  • SERVICES
    • Marketing Services
    • Reprints
    • Market Research
    • List Rental
    • Survey/Respondent Access
  • STAY CONNECTED
    • LinkedIn
    • Facebook
    • Instagram
    • X (Twitter)
  • PRIVACY
    • PRIVACY POLICY
    • TERMS & CONDITIONS
    • DO NOT SELL MY PERSONAL INFORMATION
    • PRIVACY REQUEST
    • ACCESSIBILITY

Copyright ©2026. All Rights Reserved BNP Media, Inc. and BNP Media II, LLC.

Design, CMS, Hosting & Web Development :: ePublishing