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[PSC]

I just listened to a webinar by Marc Sanchez, an FDA attorney about FSMA. FSMA is an FDA regulation and from what Mr. Sanchez said, FSMA does not apply to USDA regulated facilities. 

 

I asked Marc if FSMA would and should be covered by BRC for meat processing facilities. He said that BRC should skip over that section for meat processing. 

 

With food fraud being so new to BRC and everyone seemingly scrambling to cover this section before the Issue 7 BRC audit, has anyone in meat processing encountered BRC stating they will skip over this section? I am less than two weeks away from my audit and although I have prepared my team throughly on the subject, I am interested if anyone in the meat processing industry has gone through their version 7 audit? 

 

The other thing to note is that Mr. Sanchez stated that if you are a USDA inspected facility and your suppliers are FDA regulated, FSMA still does not apply.

[KTD]

Hi PSC -

 

Had a USDA FSIS inspected facility go through BRC v7 less than a month ago. No, the auditor did not skip over any section. There was a little leniency (depends on the auditor) regarding the depth, breadth, & implementation of protocols and programs tied to food fraud. A BRC audit should verify that you are complying the regulations that apply to your facility based on the products you produce - either FSIS or FDA (or both for a dual jurisdication facility). You may have to demonstrate how you have determined the applicable regulatory body and show either your FSIS Grant of Inspection or FDA Bioterrorism registration.

 

AFAIK, Mr. Sanchez is correct insofar as USDA FSIS - inspected facilties do not have to comply with FSMA...only FDA regulated faciliites have to do that. HOWEVER, as part of your supplier approval process, you will want to verify that your FDA regulated suppliers are meeting FSMA requirements as the applicable compliance dates roll around.

 

KTD