Tattle Tale

Remember that because of FSMA, FDA may make it mandatory for us as auditors to call FDA if we see a non-conformance in your plant.


You may want to voice your concern regarding this with FDA.





Do It Now.

You may want to consider becoming GFSI certified before your current customers ask you to.  For most it’s about a 7-8 month process.


And when you do become certified, it’s a great marketing tool for future prospects.






Are You High Risk or Non High Risk?

Under FSMA, FDA is saying that they are going to be inspecting high risk food companies once every 3 years and non high risk food companies once every 5 years.  One criteria for placing your firm in the high risk category is if you have had past problems like a recall.


So first of all you have to find out what category your company is in.  Our recommendation is not to call them but to find out on your own.


But the frequency of inspections seems curious to me.  If FDA is trying to ramp up this big huge program, it seems strange to me that they are only going to be inspecting some facilities once every 5 years.  Back in the 70’s and 80’s, we knew food processors that were being audited at a minimum of once per year.




Because of FSMA which was passed into law January 2011, any firm that processes, prepares, packs, warehouses or distributes food, must register with the FDA.  To do that go to FDA.gov.



Food Defense

How is your food defense plan coming along?  Is it ready for FDA to look at when they audit your facility?  A food defense plan is part of FSMA.


They have initiated this so that you can protect your product from intentional contamination.  Disgruntled employee stuff or a terrorist attack.  They have identified high risk facilities as being bulk liquid receiving and shipping.



FDA Listened!!!!!

FDA listened to your comments.  Congratulations!  Good job!  They changed their thinking apparently on environmental monitoring and finished product testing.  FDA doesn’t know everything.  You all in the food industry have the practical experience.  Keep your comments coming.  You have plenty of time.  YOU can make the law so that YOU can live with it.



SQF Conference

Say hello to either Jane or Jeanette at the SQF Conference in Orlando at the end of this month.  We have a table top exhibit there and at least one of them will be in the exhibit.  Maybe you can talk them out of a drink or coffee.



Training Accountability

We all have training programs.  Some good, some real good and some not so good.  What about continuous training?  If you train a line employee close to their hire date, do you ever give them a refresher?


What about accountability?  If you train a line employee on the proper way to wear a hairnet and they don’t abide, are they accountable?  Do they lose pay?  Vacation?