December survey findings from global enterprise software company Aptean showed 81% of food manufacturers are already feeling some degree of impact from FSMA regulations, either instituted or impending. The new emphasis is on proactive prevention.
The Hazard Analysis Critical Control Point (HACCP) is not new, but less familiar is HARPC, the Hazard Analysis Risk-based Preventive Controls. While HACCP is a mark to hit, HARPC is a set of controls focused on prevention processes. The food manufacturer’s current challenge is instituting and maintaining these processes to meet compliance standards.
A new culture of safety is necessary for successful compliance and prevention. Many are turning to technology for help with automation and data tracking. Technology is one of the many moving parts, but as Jack Payne of Aptean observes, “Automating poor processes will only accelerate poor results. Approaching FSMA compliance and implementing track and trace technology requires time and strategy.”
To put your proactive plan in place, Food Safety News urges manufacturers to consider the four A’s of food defense: Assess, Access, Alerts, and Audits.
Product adulteration is most likely to happen at a critical control point in your supply chain. Conduct a vulnerability assessment to identify your weakest points where someone might attempt to compromise your product.
Once you’ve identified your vulnerabilities, consider who has access to your product in these four key activity stages:
- Mixing and grinding in high volume levels
- Open-access ingredient handling
- Bulk liquid receiving and loading
- Liquid storage and handling
Restricting employee access at these points can reduce the likelihood of adulteration, and incorporating video monitoring at critical points can help identify potentially responsible parties if an incident does occur.
Increasingly accessible smart technology makes it easier than ever to connect your plant to your mobile device. The more quickly you can respond to alerts, the less likely an irreversible impact on both company and public health and safety.
Provide for regular internal and external audits to ensure your processes stay compliant. Random and third-party checks will confirm that your proactive processes keep you in compliance.
Additionally, stay in touch with the FDA’s FSMA website to keep up with impending final rules, facts, presentations, and process strategies.