Complying with USDA? 3 Reasons Why the Meat Industry Still Needs to Be Aware of FSMA

Food safety reform is sweeping the nation as the FDA enforces its most extensive regulatory shift yet. While manufacturers and suppliers across a spectrum of food categories work to align their operations with these new mandates, players in the meat industry may not be perking their ears on this particular matter. After all, meat and poultry have historically been controlled by the USDA, not the FDA. Even if you’re complying with USDA standards, however, it’s important to pay attention to what’s going on with regard to FSMA, for a number of reasons.

While the introduction of FSMA doesn’t change the fact that meat production falls under the jurisdiction of the USDA’s Food Safety Inspection Service, it does forge a closer connection between the two government entities. It also sets a precedent for the meat industry to consider the implications of FSMA as a relevant food safety initiative. Here are three eye-opening insights into the ways that meat producers may be affected by FSMA rollout, as well as valuable tips on what you need to do to be prepared.

Combination Food Producers Can Be Subject to Dual Regulatory Oversight

Production facilities that utilize ingredients from multiple industries to produce ready-to-eat and other combination foods may fall under the jurisdiction of both the USDA and the FDA. If, for instance, you’re manufacturing items that consist of meat-based ingredients in addition to produce and/or dairy products, you’re required to maintain compliance with USDA regulations and FSMA mandates to ensure that all components of your process meet the proper food safety standards.

The best way to ensure compliance with both USDA and FSMA guidelines is to implement a robust food safety program, one that prioritizes facility-wide transparency, streamlined data management and unfettered visibility at all levels of the organization. Meeting dually regulated compliance obligations doesn’t have to become an overwhelming, laborious effort. With the help of a dynamic food safety software solution, complying with USDA and FSMA regulations is a less complex, less stressful and less time-consuming requirement.

FSMA Rules Could Impact the Management of Your Supply Chain

Yes, your meat production operation ultimately answers to the USDA, but it’s possible that you have one or more suppliers that are subject to FDA regulations. This means that you’re responsible for ensuring that your suppliers are in accordance with applicable FSMA statutes. Do they have the proper Hazard Analysis and Risk-Based Preventive Controls in place? Are they following Foreign Supplier standards? Just because your facility is directly overseen by the USDA, that doesn’t mean you’re not on the hook for managing your supply chain with regard to relevant FDA-imposed rules.

To maintain the proper levels of food safety and compliance -- so as to prevent your company from facing government penalties, potential recall repercussions and reputational damage -- it is paramount to take the following precautions:

1. Evaluate your suppliers and identify any that fall under FDA jurisdiction. Conduct the necessary investigations to procure evidence of their compliance with recent FSMA mandates and make sure they are following a strict process for fulfilling their regulatory obligations.
2. Familiarize yourself with FSMA’s Sanitary Transport laws, and initiate steps to confirm that transport and delivery of all your facility’s supplies, regardless of type, are in compliance with this regulation.
3. If you work with imported ingredients, find out whether these items fall under the categories identified in FSMA’s rules for a Foreign Supplier Verification Program and implement a fully compliant plan to ensure that applicable suppliers are following the necessary safety protocol.

For more detailed information on which supplies are affected and what you must do to fulfill all of your FSMA requirements, here are some helpful resources:

• Full Text of the Law and FDA Guidance
• Article: Is Your Plant Prepared for the New Rules & Regulations of FSMA?
• Frequently Asked Questions on FSMA
• FSMA Collaborative Training Forum

The Sanitary Food Transportation Act Applies to ALL Food Categories

The FSMA rule on Sanitary Transportation of Human and Animal Food has been introduced to further protect foods from farm to table by keeping them safe from contamination during transportation. Specifically, it applies to:

• Shippers, receivers, loaders and carriers who transport food in the United States by motor or rail vehicle, whether or not the food is offered for or enters interstate commerce
• Persons (e.g., shippers) in other countries who ship food to the United States directly by motor or rail vehicle (from Canada or Mexico), or by ship or air, and arrange for the transfer of the intact container onto a motor or rail vehicle for transportation within the U.S., if that food will be consumed or distributed in the United States
• Companies involved in the transportation of food intended for export, up to the point that the shipment reaches a port or U.S. border

Even if you’re dealing strictly in meat-only products, the transportation of your food must conform to the Sanitary Food Transportation Act, which establishes rules for:

• The design and maintenance of vehicles and transportation equipment to ensure that it does not cause the food that it transports to become unsafe
• The measures taken during transportation to ensure food safety, such as adequate temperature controls, efforts to prevent ready-to-eat foods from touching raw foods, protection of food from contamination by non-food items in the same or previous load, and protection of food from cross-contact (i.e., with food allergens)
• Training of carrier personnel in sanitary transportation practices and documentation
• Maintenance of records of written procedures, agreements and training

Compliance Forecast: FDA and USDA Unite

As the food industry at large works increasingly hard to meet consumer demands for safer products, we’re going to see even greater collaboration between the FDA and USDA. As a result, it’s important for players in the meat and poultry sectors to stay tuned into food safety information from both regulatory bodies. In the end, protecting your company’s reputation and bottom line requires a committed effort to not only meet, but also exceed government-mandated standards. Dedicate your operation to maintaining a highly educated, strategic and compliant approach to food safety.

To understand how a comprehensive food safety solution supports regulatory compliance and helps minimize risk, download your CONTROL guide.