The United States represents 42 per cent of Jamaican exports, and with the increase in production of food being exported, it is mandatory that all food manufacturers and retailers comply with the United States FDA Food Safety Modernisation Act (FSMA). This mandates that foods imported from other countries be held to the same high standards required for food produced domestically. If you export or are planning to export farm produce or manufactured food products to the United States, here are some important things you need to know about the FSMA.

What is the FSMA?

The Food Safety Modernisation Act (FSMA) was originally signed into law by US President Barack Obama on January 4, 2011, to focus on effective prevention of food safety issues in the US supply chain. This act is intended to prevent food-borne illness and contamination that can spread nationally, or even internationally, given the complexity of our current supply chains. Producers, manufacturers and retailers of food, once required to register with FDA under section 415 of the Federal Food, Drug, and Cosmetic (FD&C) Act, will need to put measures in place to reduce or prevent the occurrence of food-borne illnesses.

What is required to be FSMA-compliant?

Preventative control plans should be implemented by all food facilities exporting to the United States once required to register with FDA under section 415 of the FD&C Act. If you already comply to HACCP regulations, an additional preventative control HARPC (FSMA’s Hazard Analysis Risk-Based Preventive Control requirements) is now necessary. Additionally, each facility is required to:

• Evaluate food safety hazards.

• Identify preventive steps or controls, to minimise or prevent identified hazard.

• Describe methods for monitoring the effectiveness of the controls identified.

• Maintain routine records of monitoring activities.

• Specify actions the facility will take to correct problems that arise during implementation of controls.

Training and awareness

It is mandatory that management ensures all employees who manufacture, process, pack or hold food are qualified to perform their assigned duties. This can be verified through a combination of education, training, and/or experience necessary to manufacture, process, pack, or hold food that is clean and safe. All employees must receive training in the principles of food hygiene and food safety, along with the importance of employee health and hygiene as appropriate to the food, the facility and the individual’s assigned duties.

What should the preventative control plan include?

• Hazard analysis to identify all foreseeable biological, chemical, and physical hazards must be identified

• Preventive controls for all identified hazards which must be suited for the products manufactured to significantly minimise or prevent the adulteration of food. Preventative controls include:

Process controls

Food allergen controls

Sanitation controls

Other controls deemed necessary to prevent or minimise hazards identified.

Oversight and management of preventive controls: the preventative controls must be maintained through:

• Monitoring, to ensure that preventive controls are consistently performed.

• Corrections, to identify and correct a minor, isolated problem that occurs during food production.

• Corrective actions, to identify and correct a problem implementing a preventive control, to reduce the likelihood of reoccurrence.

• Verification, to ensure that preventive controls are consistently implemented and effective in minimising hazards.

• Supply chain programme: All manufacturers must document and implement a risk-based supply chain programme if the hazard analysis identifies a hazard that requires a preventive control and if the control will be applied in the facility’s supply chain.

• Recall plan: If the hazard analysis identifies a hazard requiring a preventive control, the facility must have a written recall plan that describes the procedures to perform a recall of the product.

As mentioned earlier, each facility is required to identify hazards and document controls according to their processes. If in doubt consult with the local regulatory agencies or contract a consultant with expertise for the produce or product being exported.