A New Taste of Regulation
A New Taste of Regulation
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A New Taste of Regulation
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The Food Safety Modernization Act introduces new compliance requirements for food processing facilities, aimed at improving the quality of food inspections. The act also introduces proactive measures to prevent foodborne illness.

When President Obama signed the Food Safety Modernization Act in early 2011, it had been more than seven decades since the U.S. had enacted a law aimed at improving the quality of food inspections and introducing proactive measures to prevent foodborne illnesses.

As the number of foods available in the marketplace increases, the manner in which those foods are processed changes, and the population of "at-risk" individuals exposed to foodborne illnesses grows. New concerns surrounding food safety have surfaced.

"The current climate is right for new food-based regulations and improvements in the industry," says David Dixon, business development manager in the
Burns & McDonnell Food & Consumer Products Group. "There have been advancements in food safety over the past 10 years and a lot of new trends are forcing our clients to upgrade facilities and review operations to improve food quality."

Shifting Focus

Sparked by salmonella issues in the peanut industry that led to hundreds of illnesses and at least nine deaths in 2008, the focus on food safety has shifted to the possibility that contamination can occur within a facility.

"After the peanut recalls, increased pressure from the retail community and consumers began forcing food safety back up the food chain," Dixon says. Recommendations from groups such as the Global Food Safety Initiative, formed to provide third-party certification of suppliers who review food safety and quality issues, became broadly adopted in 2008.

Although some of the FSMA rules took effect immediately, full implementation will take three years. Emphasis will be placed on food transportation, food defense and preventative controls within facilities.

Burns & McDonnell is designing facility and process upgrades to improve food safety and to promote food defense to meet the new law.

"Many aspects that affect the design of a plant related to food safety involve ensuring an adequate lethality step and avoiding recontamination after the lethality step occurs," Dixon says. "The process requires recommending measures to manage flow of the product and taking a look at how physical spaces are isolated through ventilation, sanitation and other means."

The process also examines employee interaction with products, as well as focuses on pathogens from ingredients and packaging materials.

Burns & McDonnell has designed facilities and renovations that take all of these measures into account to allow for improved sanitary operations and food defense.

Protection First

Strengthening the barriers that protect food processing facilities from purposeful contamination, food defense measures are a vital component of the FSMA regulations. The measures can be enforced in part through security cameras, scannable ID cards and careful consideration of facility layout to monitor operations and identify potential adulteration of food.

R.J. Hope, senior physical security analyst, says the food defense plan within the FSMA presents a challenge to companies because it uses a risk-based performance standard model without a clear model for success.

"That's a double-edged sword," Hope says. "The lack of restrictions gives each company free rein in developing their own means to mitigate risks that works best for their specific environment. On the flip side, it also does not give a clear threshold to obtain compliance."

Hope says facility owners can prepare for the new regulations by analyzing potential breaches of the concentric rings of security surrounding a facility. A review of local emergency response times in relation to the time it may take to breach existing barriers can help determine additional measures that may be necessary.

"The focus should be on a security structure that addresses the traditional security philosophy of threat deterrence, threat detection and threat delay measures, and includes threat response," Hope says.

Companies will have until July 2012, when the final rules for the food defense portion of the FSMA are released, to make changes that enhance their food defense plans.

The new FSMA regulations are forcing the industry to take a thorough look at operations and facilities and modify designs and processes.

"This is a complicated regulation that our clients are up against, and we have a unique capability to sort through it and provide guidance on improvements that will be necessary," Dixon says.

For more information, contact Paul Menne, 770-510-4520.

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