Is FSMA living up to its intent?
It seems as though there are more and more recalls regarding pathogens in both human and pet food. These seem to be across all categories. If FSMA was put in place to ensure manufacturing is done with the appropriate preventive controls, why does it seem that there are so many recalls that could be prevented? I have heard (and said) that the system is just finding it now, but is this really true? Is the system finding more, or are we just finding new ways to thwart the process that was implemented with FSMA?
I don't think the FDA is equipped to fully enforce FSMA. Other non-governmental organizations (ISO, SQF, GMP cert bodies) typically have more frequent and stricter inspections than the FDA, but even then I feel there are loopholes for a dubious business to exploit. A general shortage of auditors in the industry (so I've heard) likely exacerbates the issue. Businesses can exploit these loopholes until bad practices result in wildly out of specification product that cannot be dealt with in any other way besides a recall.
That said, I wonder how many of the recent recalls happened at facilities that were only FDA registered, vs facilities that also had other 3rd party certifications?
It's a complicated issue with many variables. A few off the top of my head. The facilities good be testing more because of the standards. More testing = more likely you'll find something. Some facilities could have seen the fallout with the baby formula and be upfront about their results. The job market is crazy in the US. Changeover in employees usually means more problems. COVID shut down on-site inspections. Now they need to catch up. Summer time in the US = warmer temperatures. The USDA acknowledges this and requires more testing during summer months.
I recently made some new slides for my FSPCA training since they are outdated. Based on FDA reported recalls/alerts (2018-2021)- no changes in number of recalls but there was an increase in allergen recalls. Typically reporting in at 1/3 of annual recalls it is now at 1/2 (in 2021). Labeling errors are the main reason rather than cross-contact so there may have been some improvement with cross-contact.
I agree with BrothBro - the FDA can't handle the workload and they only lay down the hammer when shit hits the fan. Congress even called them out for not using their recall authority that was granted to them enough - these voluntary recalls are a joke when its really being forced. The cost of food safety is too high to make some products profitable so its basically all a balancing act and when companies begin to choose filling orders over master sanitation and maintenance that's when things begin to spiral out of control. You skip one down day they think you can always skip it. Sales and production always wins unless you put your foot down - don't give them the slack they are asking for because they'll never give it back.
You can also have a great food safety plan - but they are never really fully implemented and trained on either.
The cost of food safety is too high to make some products profitable so its basically all a balancing act and when companies begin to choose filling orders over master sanitation and maintenance that's when things begin to spiral out of control. You skip one down day they think you can always skip it. Sales and production always wins unless you put your foot down - don't give them the slack they are asking for because they'll never give it back.
You can also have a great food safety plan - but they are never really fully implemented and trained on either.
IMHO the line from Kara that is in BOLD is right at the heart of the issue
If a company DOES NOT included food safety management into the cost of doing business right from inception, that will ALWAYS equal issues
This comes down to culture of doing business. Lots of companies around the world have stellar food safety track records because they embrace food safety rather that think of it as an after thought
I recently made some new slides for my FSPCA training since they are outdated. Based on FDA reported recalls/alerts (2018-2021)- no changes in number of recalls but there was an increase in allergen recalls. Typically reporting in at 1/3 of annual recalls it is now at 1/2 (in 2021). Labeling errors are the main reason rather than cross-contact so there may have been some improvement with cross-contact.
I agree with BrothBro - the FDA can't handle the workload and they only lay down the hammer when shit hits the fan. Congress even called them out for not using their recall authority that was granted to them enough - these voluntary recalls are a joke when its really being forced. The cost of food safety is too high to make some products profitable so its basically all a balancing act and when companies begin to choose filling orders over master sanitation and maintenance that's when things begin to spiral out of control. You skip one down day they think you can always skip it. Sales and production always wins unless you put your foot down - don't give them the slack they are asking for because they'll never give it back.
You can also have a great food safety plan - but they are never really fully implemented and trained on either.
IMHO the line from Kara that is in BOLD is right at the heart of the issue
If a company DOES NOT included food safety management into the cost of doing business right from inception, that will ALWAYS equal issues
This comes down to culture of doing business. Lots of companies around the world have stellar food safety track records because they embrace food safety rather that think of it as an after thought
The sad truth BUT we're all here to promote the change for an effective food safety culture :) I think FSMA has the foundation to be extremely effective. There have likely been improvements in some areas, but there is still work to be done.
Balance the responsibility across all depts. ---> Train on the why we do, not just how to do the job/task --> Accountability