Food Protection Trends - July/August 2018 - 306

human food plans. He described how teams of students
develop a "systematic, logical protocol" for their HACCP
and PC plans and evaluate those plans in terms of mandatory
requirements and scientific credibility (1).
The classroom discussions and individual assignments
are not based on hypothetical scenarios. Rather, students
are matched to small- and medium-sized processors from
the Midwest region that have requested help with their
HACCP/PC plans. As part of their coursework, student
teams make site visits and meet with industry professionals,
and many of them are subsequently hired on as summer
interns or as consultants after completing their studies (1).

FSMA requires that suppliers of the food industry verify
that risks are controlled. To meet this mandate, the use of
approved suppliers, as well as verification that suppliers
control risks, was suggested. Documenting supply chain risks
by combining ingredient and supplier risks into a combined
metric to determine an overall material risk score was also
illustrated. Operators can use this risk score to document
their decisions about suppliers and their products and
include the score as part of their overall preventive controls
plan. The presenter concluded his presentation by stating
that compliance with FSMA rules would lead to industries'
reduction of their brand risk (3).

Implementing FSMA: Food industry challenges
Dr. Peyman Fatemi is Vice President of Scientific Affairs
for TAG, a global food and beverage safety consulting
company. He presented the industry perspective on how
the FSMA rule for human food preventive controls has
transformed hazard prevention within the food industry. The
FSMA preventive control rules for human and animal foods
represent the basic regulatory requirements of the overall
FSMA law. Within these rules, there is a specific focus on
suppliers of imported foods, which Dr. Fatemi identified
as one of the greater challenges for organizations working
toward FSMA compliance (5).
The philosophy of ensuring food safety through prevention is essentially the core of FSMA, which mandates
that all companies create a food safety plan to mitigate
hazards (5). In his presentation, Dr. Fatemi illustrated
how a proper food safety plan works within an organization, beginning with training personnel how to identify
and analyze hazards. Once potential hazards are identified, his sample plan moved to preventive controls,
including supplier controls, followed by monitoring,
corrective actions, verification and then reanalysis. FSMA
requires facilities to maintain records and make them
available upon request. Recording each part of an operation's food safety strategy, and reviewing it regularly, is
truly at the center of any successful food safety plan.
Dr. Fatemi illustrated how facilities could structure their
operations to ensure food safety. Operations first must
prevent contaminants from entering the facility, through
control of raw materials and pests, as well as construction
and visitor procedures. The second step consists of removing
contaminants through cleaning, sanitization, and use of
sanitary design for equipment and facilities. Following
this step, the control of water, time and temperature, using
sanitary design for facilities and equipment, and controlling
contamination through adequate frequency of cleaning
and sanitation, is key for successful compliance. His final
recommendation was with regard to controlling food
contaminant transfer, which is achieved through the control
of vectors (air, contact surfaces and water), sources (niches),
and raw material and personnel traffic patterns (3).

The voice of the stakeholder in the new regulatory
framework
Dr. Michelle Danyluk is the Principal Investigator for
the Southern Center for Training, Education, Extension,
Outreach and Technical Assistance to Enhance Produce
Safety. This center, a part of the Institute of Food and
Agricultural Sciences at the University of Florida, works to
build a collaborative infrastructure in the southern region
of the country to support FSMA training, especially for
the produce industry. Her presentation reported on the
stakeholder perspective and commitment to FSMA rules
for produce safety, foreign supplier verification, and thirdparty accreditation.
To obtain data relative to stakeholder perspectives and
commitments, Dr. Danyluk and her team identified regional
stakeholders and provided them with specific technical
assistance and FSMA training information. By doing so, the
Southern Center hoped to forge strong partnerships within
the region to improve capacity building and to increase the
potential for future FSMA trainings. A questionnaire was
administered to stakeholders to identify their perceptions
of challenges to FSMA compliance. The results of the
questionnaire identified challenges as cost of compliance,
current knowledge of FSMA, and participation in FSMA
trainings. It also addressed producers' perceptions of,
and attitudes toward, the FSMA and the availability of
information about the FSMA. About 80 percent of the
stakeholders surveyed were industry members, while
the remaining 20 percent consisted of extension agents,
specialists and consultants (2).
Of those responding to the questionnaire, one-third had
attended no food safety training during the previous year.
Another 49 percent had attended one or two trainings.
Respondents noted that their most common perceived
challenges to FSMA compliance were producers' current
knowledge of FSMA, as well as costs of compliance to
producers. According to the presentation, 80 percent of
respondents said that extension's ability to provide training
on FSMA was not a significant challenge.
Dr. Danyluk and her team also used the questionnaire to
understand challenges associated with the FSMA within

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Food Protection Trends July/August

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