I just returned from an FDA meeting in Silver Spring, Maryland. There, I attended an open meeting entitled FDA Food Safety Modernization Act: Title III – A New Paradigm for Importers. FDA members were the primary presenters, and they focused on the newly passed laws meant to enhance food safety. The forum was created to provide attendees the opportunity to discuss the implementation of import safety provisions found in the new Food Safety Modernization Act (FSMA).
The presentations focused on four different parts of the new legislation including:
- Foreign supplier verification program
- Voluntary qualified importer program
- Import certifications for food
- Third-party accreditation
The core of the new legislation was described as a means of preventing rather than reacting to food safety problems. Throughout the day, a mantra seemed to be repeated by almost every speaker: Collaboration and partnering among industry, foreign governments and exporters is critical to making the new laws successful and further protecting the global food supply chain.
While I enjoyed the presentations, my background had me noodling over the idea of “preventing” food safety issues. While supplier verifications, qualifications, certifications and 3rd party accreditations are all certainly part of creating a system of prevention, no one discussed process or manufacturing controls that could be used for prevention. As one might expect, most of the discussions focused on audits, certifications and inspections. However, coming from an industrial statistics perspective and having implemented SPC in a number of food manufacturing facilities, I was surprised that there wasn’t any mention of process control technologies. The methodologies presented occur “after the fact” and aren’t geared towards in-process detection and prevention. Given the proven efficiencies that are gained from quality information systems, I would have assumed that there would have been more discussion on preventative technologies and predictive analysis.
For example, rather than wait for an inspector to find a problem, how about the food manufacturers themselves deploy process control technologies in their plants? If so, these technologies could be used to generate an alarm at the moment the issue occurred. But I didn’t hear much discussion about this.
Instead, the presentations focused on how food manufacturers would rely on certificates and how companies should be required to provide safe food guarantees. OK, fine. Proper documentation is undoubtedly necessary as are guarantees. But if a food shipment arrives at our shores in the USA, gets inspected by an FDA agent at the dock and then rejected, what is the result?
Well, yes, that shipment would then be prevented from getting into our food supply. And that’s good. But what if that shipment came all the way from China? The expenses associated with shipping, scrapping and fixing those food safety problems after FDA inspection seem to be extraordinary. If we want to prevent food safety issues, why not start closer to the source? How about having critical quality checks where the food products are made? Therefore, if an alarm is generated, the issue could be identified and eliminated at the time the product is actually manufactured – before it is shipped across seas.
The foreign food manufacturer could perform food safety checks, HACCP checks and other critical data collections. This data could be made available electronically in a standard format to those who must have access to it (such as the importer or even the FDA). Then, after the product is shipped, the FDA agent on the dock could simply confirm that the requisite food safety checks were performed by the foreign manufacturer.
While the methods that the FDA presented are certainly useful and will help make our food safer, I think we should take it a step further and be even more proactive about identifying potential issues sooner. Many of our customers have systems in place to conduct these preventative quality checks and they are not only ensuring food safety, but also dramatically reducing the costs of quality.