Preventive Controls for Human Food Rule: Are You Prepared for it?

For many food companies, the Food Safety Modernization Act (FSMA) compliance date for the Preventive Controls for Human Food (PCHF) rule is September 2016. This rule has the most impact on your manufacturing operation, however, there are several rules that have been released under the FSMA legislation, in addition to the PCHF rule, that have different compliance dates – and all need to be evaluated to determine the impact on your business.

Start Preparing Now!

For those companies that are required to comply with the Preventive Controls for Human Food (PCHF) rule in September 2016 – you should be working on your Food Safety Plan now. The first thing your firm should do is evaluate your status under the new law (based on company size, sales and what you make or import). For those companies that are required to comply with the PCHF rule, there are some changes you will need to make:

  1. Identify your Preventive Controls Qualified Individual (PCQI) and have them attend an FSPCA Preventive Controls for Human Food course. This certificate course will provide them with the overview of the regulation and how to implement it in their facility.
  2. Plants should create their written, facility specific food safety plan. This food safety plan needs to contain a written hazard analysis (you can include your HACCP plan), written documentation of any preventive controls that are needed along with a recall plan.

General Mills has a small team that is accountable for the implementation of all of the FSMA rules. You may need to assign a dedicated resource (typically your PCQI) to really understand and implement the rules. Your food safety team should perform a gap analysis between your current programs and the rule requirements and begin working towards closing those gaps.

During the Quality Performance Leadership Summit on May 17th at Johnson & Johnson, we will discuss some key highlights of the rule and some practical ways you can get your HACCP plan aligned with HARPC (hazard analysis and risk-based preventive controls). This will be a great opportunity to hear how General Mills and other food companies are implementing the rules.

Lauren Wilson