Specialty Food Magazine

Spring 2017

Specialty Food Magazine is the leading publication for retailers, manufacturers and foodservice professionals in the specialty food trade. It provides news, trends and business-building insights that help readers keep their businesses competitive.

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BY RON TANNER special section A s the deadline for Food Safety Modernization Act compliance draws closer for small and very small businesses, you need to look at the management of your supply chain as an essential step to ensure that the food you sell is safe. Steps for every small business to take to comply with the new rules. Managing the Supply Chain for Food Safety Modernization Act Compliance The FDA has granted extensions for small and very small businesses to comply with FSMA. Small businesses are defined as companies with fewer than 500 employees; their compliance date is September 2017. Very small businesses, with less than $1 million in annual sales over the past three years, have until September 2018. However, some distributors and retailers are encouraging compa- nies to comply sooner, so the time to start is now. The Supply Chain and Your Food Safety Plan Every food manufacturer must create a written Food Safety Plan and operate based on that plan. A Preventive Controls Qualified Individual must author the plan. A person can become a PCQI by completing the training courses offered by the Food Safety Preventive Controls Alliance, or through work experience. The Food Safety Plan can include preventive controls administered along the supply chain, especially when an ingredi- ent has a history as a hazard. The PCQI makes this determi- nation when he or she does a hazard analysis, which identifies where the possibility of unsafe food occurs within the production process. Some ingredients, such as vinegar, do not have a safe- ty hazard; others, such as spices, can come into your facility with serious food safety issues. You do not need a supply chain program if the preventive control for that hazard is applied within your facility. Often, the hazard can be controlled before the ingredient enters your manufacturing facility. Companies from which you purchase ingredients are most likely to apply supply chain preventive controls, but, in some instances, companies to which you sell your product can apply them. The control of a hazard—and your respon- sibility to make sure the control had been applied—is the basis of your Supply Chain Program. The FSMA regulation defines the supply chain as consisting of Supplier, Receiving Facility, and Customer. The manufacturer/ processor is the Receiving Facility. Your Supplier can be a manu- facturer/processor, importer, farm, or ranch that provides the raw ingredients. Your Customer can be another manufacturer/processor or a foodservice or retail establishment. A Supply Chain Program is not required when: • No hazards exist. • Receiving Facility controls the hazard. • Customer or others down the supply chain control the hazard. Requirements of Your Supply Chain Program The regulations state five general requirements for controlling your supply chain: • Use approved Suppliers. • Determine Supplier verification activities. • Conduct Supplier verification activities. • Document Supplier verification activities. • If necessary, verify a supply chain control applied by an entity other than your Supplier. The requirements are simple, in theory, but will require time and diligence to implement. 86 ❘ SPECIALTY FOOD MAGAZINE specialtyfood.com

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