Over the course of my 36 years with The Hershey Company, I helped lead and execute a number of global Quality, Regulatory, and Governance initiatives. Perhaps one of the most challenging, and yet rewarding, was implementation of the Food Safety Modernization Act (FSMA).
When the FDA published the proposed rules in 2011, we had a very robust food safety program in place. The first question senior management asked was, “how close are we to being compliant?” At the time, there were still a lot of unanswered questions. But, like many food companies, generally speaking we thought we were in pretty good shape – maybe 85% to 95% “there.” We initiated a FSMA working group within Hershey to identify potential gaps and develop associated action plans in preparation for the final FDA rules. Thus began a five-year marathon to move us to full compliance with FSMA. There are three lessons we learned along the way that might prove helpful to others as they make this same journey.