FSMA Fridays: Preventive Controls For Human And Animal Food (Part Three Of Five)

Check Out Part One and Part Two Of This Series

In the second portion of FSMA Fridays: Preventive Controls For Human And Animal Food, SafetyChain’s Jill Bender began speaking with The Acheson Group’s Dr. David Acheson and Rolando Gonzalez about environmental controls and their requirements under FSMA, as well as the FDA’s approach to supply chain controls. Here, in the third installment of the series, the trio continues the conversation about FSMA’s final rules regarding preventive controls for human and animal food mentioning how GFSI helps with FSMA compliance and some tips to help your company comply with the rules.

Jill: I know you touched on this already at the kick off, but again, just to come back to this, as far as from GFSI compliance, has the FDA determined that that is equivalent to FSMA compliance?

David: I did mention it, Jill, as you said, and I mentioned it because it's a question that is coming up all the time and there are lots of companies that obviously are GFSI compliant, an increasing number due to a variety of reasons, and that's an obvious question. So, the FDA did specifically addressed this and what they have said is that, basically, to the extent that an existing plan, and they don't just say GFSI, they actually mention a HACCP plan, so if you have an existing HACCP plan, or a GFSI compliant food safety plan, and you can use that to meet the requirements of the rule. But, it does say, and you're relying on the existing records, but they make it very clear that you may have to supplement, as necessary, to demonstrate compliance with the new preventive control.

Now, to me, they called it out and said, because so many people were asking the question and I think they basically told us, what they are thinking. My view of this is that it really is not any different from what we have been saying all along. If you are GFSI compliant, you are a long way to meeting the preventive control rules and many colleagues on the phone will know that we at TAG (The Acheson Group) have done comparative analysis. We looked at some of the major GFSI standards and done the comparisons — how do they shape up against the proposed preventive control rules? They shaped up pretty well, and that is common information.