After five years of listening sessions, draft rules, comment periods, discussion, analysis, planning, and compromising, the rules are final and the first compliance date for the Food Safety Modernization Act (FSMA)has arrived. It’s here, it’s now, and it’s real!
Many food companies began their move towards compliance when the preliminary rules were first published in late 2011. A lot of companies, however, waited until the final rules were issued last fall, leaving themselves only 1 or 2 years to comply with the Preventive Controls for Human Food rule, depending on their size. Regardless of when they started, much of the focus has been on "what" needs to be accomplished … understanding and interpreting the rules. Of course, this is crucial. There are a lot of excellent resources available to help companies, including those outlined in Sarah Geisert’s recent post. But as Llaine Groninger noted, based on her experience at The Hershey Company, and as I’ve seen as a YourEncore Consulting Partner helping our food clients in their FSMA journey, the real challenge is in “how” to achieve compliance. And nearly all companies, both large and small, have discovered that the “how” is more complex, time consuming and resource intensive than they anticipated.
So, how do you get started on the “how"? Here are 3 areas of focus and a process I follow to help clients get past “what” and on to “how”.