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Food Safety Plan for Distributors (FSMA)


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Posted 10 May 2018 - 06:32 PM

Good morning everyone,


I am developing a food safety plan for a distribution facility following the modified requirements section of PCHF rule.

Unfortunately, I am having trouble in properly identifying the information I will need and how it will be organized. Since we only distribute we only have three process preventive controls: receiving, storage, and shipping. I believe these are the only preventive controls I will need to include in this food safety plan as the modified requirements only calls for temperature control (part of the process preventive controls; receiving, storage and shipping). Meaning I will not need to include the other preventive controls; food allergen preventive controls, sanitation preventive controls, and supply-chain preventive controls. These are already implemented through our GMPs and other pre-requisite programs either way. 


Does anybody know if this is correct? in other words, are process preventive controls the only controls necessary for distributors who store unexposed packaged food? 


Also if this is correct, since we have many different products but they all follow the same process preventive controls for temperature  (receiving, storage and shipping) will I need to separate these products during the product description even though the food safety plan will ultimately be the same for all products. 


§ 117.206 Modified requirements that apply to a facility solely engaged in the storage of unexposed packaged food.

(a) If a facility that is solely engaged in the storage of unexposed packaged food stores any such refrigerated packaged food that requires time/temperature control to significantly minimize or prevent the growth of, or toxin production by pathogens, the facility must conduct the following activities as appropriate to ensure the effectiveness of the temperature control...

I will really appreciate any advice, 

Thank you. 




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Posted 10 May 2018 - 09:02 PM

You hit it. With unexposed packaged food the only preventive controls in your plan will be time/temperature process controls for perishable goods or goods which have temperature/humidity requirements to control other hazards (e.g. mold growth/aflatoxin/patulin).

Austin Bouck
Owner/Consultant at Fur, Farm, and Fork.
Consulting for companies needing effective, lean food safety systems and solutions.

Subscribe to the blog at furfarmandfork.com for food safety research, insights, and analysis.

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Also tagged with one or more of these keywords: #FSMA, #DISTRIBUTION, MODIFIED REQUIREMENTS

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