In defending food safety procedures and practices to an inspector who is challenging them, it is best to have multiple sequential "rings of defense." This means that the easiest changes are suggested first, with more costly and difficult changes suggested later. Doing this strategically has the advantage of minimizing changes to the procedures and practices, and potentially avoiding a costly recall or market withdrawal.
Through a voluntary pilot program, the U.S. Food and Drug Administration (FDA) found four major third-party industry auditing standards for food safety to be in alignment with both the Preventive Controls for Human Foods Rule and the Produce Safety Rule, which are FDA regulations that were issued as part of Food Safety Modernization Act (FSMA) implementation.
