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Explore This IssueFebruary/March 2012
In addition to working within your own company to prevent outbreaks, all food companies should also be working with others in their industry to enhance food safety generally. Sharing best practices, as well as mistakes made, benefits all food companies within any sector of the industry.
In turn, once a problem is identified, all ingredients used to make that product become suspect, as well as all of the downstream foods in which that product is used. A single recall can easily affect dozens—if not hundreds—of food companies. Moreover, each of the negative effects resulting from outbreaks is amplified by food recalls. To the extent food companies can work together in discrete segments of their respective industries to reduce recalls by improving overall quality and collectively sourcing from trusted suppliers, the better off all companies will be.
No, we didn’t forget. Food regulation will also affect food companies in 2012. The FSMA gave the FDA substantial new powers and directed the agency to use them. Although we will probably see substantial changes in the way the FDA does business this year, the most notable change will occur in July, when the agency begins enforcing its new written food safety plan requirements. Expect the FDA to focus a substantial amount of public attention on the enforcement activities the agency directs toward a select few companies this summer, as it proves to the nation that its new authority is necessary and is working. Work internally to find ways to enhance your relationship with the FDA, and make sure you do not become one of those unfortunate companies.
Finally, expect food safety to continue to influence your company more than ever. From a food safety standpoint, our industry is healthy but, at the same time, arguably frail. Although the challenges we face will continue to grow due to an increasing number of outbreaks, recalls, and reactive new laws, new solutions and opportunities will emerge and multiply. Food safety technologies will be improved, food safety information will be more widely disseminated, food safety regulation will be formalized and understood — and, one hopes, food safety enforcement will become standardized and food safety enhanced.
So let’s not be discouraged by the ground-level fog. Although it may be difficult to predict the exact wording of the FDA’s next regulation, the health and direction of our industry as a whole is more important. As long as we have a general idea of the global factors that will influence our future, we have a better chance to decide the direction we should ultimately go.
Stevens, an attorney at Gass Weber Mullins LLC in Milwaukee, Wis., counsels food industry clients nationally on food safety regulatory and liability issues. He can be reached at email@example.com or (414) 224-7784.