Stupid Pathogens

In the US it is reported that each year there are 9 million episodes of foodborne illnesses from known pathogens, and there are 38 million episodes from unknown pathogens.  This equates to 48 million illnesses annually, 128,000 hospitalizations and 3,000 deaths.


We have just left a meeting and we have been assured that researchers are working very diligently to reduce these numbers.


Way Too Much Paperwork/Recordkeeping

One thing we know for sure, and that is FSMA is promising a lot more paperwork and record keeping.  People that we have spoken with are talking about hiring more people to keep up with this.


There are automated systems out there to help you keep up with these new requirements that are geared towards FSMA.


I’m Sorry

In the last few posts, we have been throwing at you a lot of new stuff on FSMA.  Here is another new item.


A new provision of FSMA is for you if it is appropriate in your facility to have a HARPC plan or program.  Hazard Analysis Risk-Based Preventive Controls.  In a HACCP plan there are critical control points that we can measure, but in a HARPC plan hand washing might be a critical step to control risk.


Sorry.  Call if we can help.


Know Your Undeclared Allergens

Fifty percent of all FDA food related recalls are because of undeclared allergens.  50%!  15 million Americans have some sort of food allergy.


The most common foods involved are bakery products, snack foods, candy, dairy products and dressings.


The most common allergens are milk, wheat and soy.


Are any of these allergens ingredients in your product?


Dog Lovers Beware

Some folks are alleging that their dogs have become sick and died from Beneful dog food.


If you are using this product you need to research and make a decision.


What Is HARPC?

HARPC stands for “Hazard Analysis and Risk-Based Preventive Controls”.  It is one of the new provisions of the FDA Food Safety Modernization Act.  HARPC requires every food manufacturer and storage facilities to identify food safety and adulteration risks associated with their foods and processes, to implement controls to minimize the risks, to verify that the controls are working, and to design and implement corrective actions to address any deviations from the controls that might arise.  This plan must be documented, periodically reviewed, maintained and it’s verification steps documented.



W-A-A-A-A-Y Too Long

This FSMA thing actually coming to fruition is just taking way too long.  They are still considering proposals.  I read something yesterday that said they think that things might start moving in 2017.  The Act was signed in 2011.


And now the Fed wants to get involved (tax) the internet or it’s users?  They are already trying to or controlling health care.


These guys are too much.



FDA – Gone

Sen. Dick Durbin and Rep. Rosa DeLauro have introduced a bill in Congress that would establish a single, independent federal food safety agency.  Food safety oversight is currently split up among 15 agencies.  Durbin and DeLauro want to create the “Food Safety Administration”.


If this passes, in our opinion, this will further prolong real enforcement of FSMA.  Heck, it’s already been 4 years and nothing has happened!




FSMA (Food Safety Modernization Act) now requires that all facilities that holds, prepares, packs, warehouses, distributes, manufactures, bottles, cans, etc foods have a HACCP plan or food safety plan.


If you haven’t, start on yours today.  This is a must.



FDA in 2015?

They will probably still be finalizing their proposed rules.  So taking an educated guess that there will  not be a lot of audits.  We recommend that you be ready for them in the later half of 2016.

*  You should have programs set up for all of your preventive controls.

*  You should monitor your programs and your supply chains’ programs.

*  You should have a program for your corrective actions.

*  You should have a program that is easily accessible for your documents.

*  You should have an environmental monitoring (mentioned in this blog earlier) program.

*  You should have a mock audit for all of the above.