Food Safety
search
Ask Food Safety AI
cart
facebook twitter linkedin instagram youtube
  • Sign In
  • Join Today
  • Sign Out
  • My Account
Food Safety
  • NEWS
    • Latest News
    • Food Safety Five Newsreel
  • PRODUCTS
  • TOPICS
    • Contamination Control
    • Food Types
    • Management
    • Process Control
    • Regulatory
    • Sanitation
    • Supply Chain
    • Testing and Analysis
  • PODCAST
  • EXCLUSIVES
    • eBooks
    • Sponsored Insights
    • Sponsored White Papers
    • FSM Distinguished Service Award
    • Interactive Product Spotlights
    • Videos
  • MORE
    • BUYER'S GUIDE
    • NEWSLETTERS >
      • Archive Issues
      • Subscribe to eNews
    • Store
    • ASK FSM AI
  • WEBINARS
  • FOOD SAFETY SUMMIT
  • FSM FEATURES
    • FSM Features Collection
    • eMag Archives
    • Editorial Advisory Board
    • Contact
    • Advertise
  • JOIN
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...
    Meat/Poultry
    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...
    Personal Hygiene/Handwashing
    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...
    Management
    By: Maria Cristina Tirado Ph.D., D.V.M. and Shamini Albert Raj M.A.
Manage My Account
  • Join Food Safety Magazine
  • Manage My Preferences
  • 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
  • pre-packaged salads, noodles, and prepared meals stocked on multi-tier grocery store refrigerator shelves
    Sponsored byCorbion

    How Many Days of Shelf Life Are You Leaving on the Table?

  • Top view portrait of two factory workers standing by conveyor belt during quality inspection at food production, copy space
    Sponsored byFlexXray

    Foreign Material By the Numbers: What the 2026 Benchmark Report Reveals

  • a conveyorized industrial metal detector system that appears to resemble a Loma Systems IQ4 Metal Detector setup with an integrated conveyor belt and control panel for food or package inspection.
    Sponsored byMettler Toledo

    Beyond Detection: How to Avoid Physical Contamination in Food Through a Smarter Inspection Strategy

Popular Stories

choosing food in the freezer aisle

Refrigerator Malfunctions on U.S. Military Bases May Be Result of Targeted Cyberattacks, Similar to French Incident

supermarket freezers

Another Wave of Refrigerator Cyberattacks Sweeps European Grocery Stores, Causing More Food Losses

doctor talking to patient

U.S. is Making Little Progress Toward 2030 Foodborne Illness Reduction Goals, Data Shows

allergens ebook

Events

November 12, 2026

From Data Overload to Actionable Food Safety Risk Intelligence

Live: November 12, 2026 at 11:00 am EST: This webinar explores how data integration, advanced analytics, and digital technologies can help transform disparate information into meaningful risk intelligence.

November 17, 2026

Are You Getting the Most from Your Food Safety Testing?

Live: November 17, 2026 at 11:00 am EST: Attend this webinar to explore practical ways food processors can modernize sanitation verification and microbiological testing while keeping workflows simple and effective.

December 2, 2026

Beyond Surface Clean: Tackling Biofilms and Persistent Pathogens

Live: December 2, 2026 at 11:00 am EST: Attend this webinar to understand why chlorine dioxide is not chlorine, and what “ultra-pure” means for residues, byproducts, and effectiveness.

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

  • Institute for Food Safety and Health (IFSH) - Illinois Tech

    IFSH is a one-of-a-kind applied food science research consortium comprised of the Illinois Tech, the U.S. FDA, and the food industry. In collaboration with the FDA, we provide stakeholders with the opportunity to develop and exchange knowledge, experience, and expertise in the areas of food safety, food defense, and nutrition.
  • Schneider Food Safety Services

    We are a boutique regulatory (FDA/USDA) consulting firm, and we support companies with FSMA 204 traceability compliance and other regulated processes.
  • The Food Safety Professionals Group (The FSPG)

    Educate, Engage, Elevate. Through networking events and virtual education sessions, the FSPG supports students and young & seasoned professionals with mentorship and career opportunities.
×

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

Newsletters | Website | FSM Features Collection

JOIN TODAY!
  • RESOURCES
    • Advertise
    • Contact Us
    • Directories
    • Store
  • JOIN TODAY
    • Create Account
    • FSM Features Collection
    • Newsletters
    • Customer Service
    • Manage Preferences
  • SERVICES
    • Marketing Services
    • Reprints
    • Market Research
    • List Rental
    • Survey/Respondent Access
  • STAY CONNECTED
    • LinkedIn
    • Facebook
    • Instagram
    • X (Twitter)
    • YouTube
  • 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