While the Food Safety Modernization Act was passed into law six years ago, it was not until September 2016 that compliance began for large food companies. Small CPG companies have another 12 months from then to comply, and very-small companies have a year beyond that. The top-of-mind questions for many CPG companies are “What do I need to do for FSMA and when?” With these pending regulatory developments looming, it’s a good time to plan how to move forward. CPG companies should plan to include the help of OEMs (original equipment manufacturers). OEMs offer an important resource to CPGs in the common goal of removing and reducing food safety risks from the production process. The fundamental concept imbedded in FSMA is prevention of food safety hazards. These hazards, if left unchecked, can lead to all sorts of risks for CPG companies and consumers. For example, food safety hazards can cause illness, injury, disease, loss of product, loss of operations, recalls, fines, incarceration and litigation. Removing or reducing the risk of these happening is a shared goal and a good opportunity to partner, resulting in a joint risk reduction effort between CPG and OEM companies.
FSMA has lots of bells and whistles, but it also drives home the importance of good manufacturing practices (GMPs) which promote the concepts of sanitary equipment design and sanitary plant design. The plan for this joint effort should start with the fundamentals of a good food safety system. FSMA, like its predecessor HACCP, will only operate efficiently if the plant environment provides a sanitary place where food can be made and held safely until shipping. This network of GMPs, now described in FSMA Part B rules, ensures the plant will have a good foundation of food safety control that allows FSMA to manage the critical preventive control measures. Without this background of sanitation control, all sorts of problems can exist, and even the best food safety plan will fail to be truly effective.
The joint effort to reduce risk can begin with a discussion on a common understanding of the minimum or basic parameters equipment must meet to give the food safety performance CPG companies need. To tackle the issue of several sources of sanitary design standards and a desire to develop a single set of basic sanitary design guidelines, the PMMI OpX Leadership Network’s Engineering Solutions Group developed a document titled: “One Voice for Hygienic Equipment Design for Low-Moisture Foods.” The purpose of the document was to utilize existing industry standards, guidelines and information to define a process that allows CPGs and OEMs to reach consensus on design criteria for hygienic equipment for low-moisture food manufacturing. The joint industry approach was a way to streamline the activities of developing basic design specifications and criteria to move the conversation from a “blank page” situation to a common criteria level. With agreement on general design criteria, reaching a consensus on the basic criteria needed to satisfy current and future equipment hygienic design criteria could be met more efficiently. As this One Voice document gains acceptance and utility in the industry, it helps satisfy the goal of reducing risk through a CPG and OEM partnership. The base level, of course, is just the minimum needed to meet FSMA’s GMP sanitary design needs. Many companies find this platform is a conversation starter that leads to more discussions on reducing risk from food safety hazards—the common goal of CPGs and OEMs alike.