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Beyond FSMA: How to further cut risk

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Editor’s note: This article is the last in a three-part series.
With initial deadlines for the first two major FSMA (Food Safety Modernization Act) regulations just passing, it’s the right time to consider what happens next with food safety in America.

Editor’s note: This article is the last in a three-part series.

With initial deadlines for the first two major FSMA (Food Safety Modernization Act) regulations just passing, it’s the right time to consider what happens next with food safety in America.

Even though it will be a year before enforcement of these two rules begins, there is no time to waste in tackling compliance and reducing risk. The two Preventive Controls rules (human and animal food) that were recently released are only the first two of the seven major regulations that will create more questions than answers for executives in the C-suite over the next few years. In over 2,000 pages the regulations manage to create new definitions, adjusted requirements and increased complexity. For senior executives, FSMA has been likened to Sarbanes-Oxley, making them ultimately responsible for their supply chain’s compliance.

Complying with what’s next will be at the heart of the efforts to ensure a safe food supply as the industry scrambles to understand and meet FSMA guidance. Adding the new kinds and types of records FSMA will require only multiplies the amount of documents that growers, manufacturers, shippers, wholesalers and retailers are currently trying to maintain. Combining efforts across all departments, companies can manage not only food safety documents but compliance documents for the entire organization — think OSHA, DOT, EPA, etc. These now can and should all be managed in one location, and by fewer people.

Some consider an electronic repository enough, while others see the value in proactive exception-based alerts and notifications and functionality that leverages email to receive, capture and store records. Advancements in managing documents are just beginning. These include optical character recognition processes that read inside of documents, comparing them to established criteria and executing work flows based on results. The green solution of e-signing a document enables the requestor to provide a digital document that can collect information plus confirmation that the document was read, all without the felling of a single tree.

While FSMA moves to a preventive stance by proactively requiring proof of compliance through documentation, let’s not forget the Food and Drug Administration’s one-forward, one-back requirement for tracing product purchases and sales. Extending the capability beyond one up or back can and should be applied. This will help companies gain visibility to product movements through their entire supply chain not only for safety and compliance purposes, but matching supply with demand at the store level. Technology now exists that does not require the use of standard identifiers, yet enables a single ingredient to be tracked completely through its supply chain both forward and backward. It doesn’t matter if the ingredient changes shape, size or name, or becomes an ingredient in another product. Trade secrets can now also remain hidden through use of alias naming.

Looking forward, it’s clear that technology will play a major role in enabling merchants to further reduce risk and improve compliance beyond FSMA by taking that compliance data and linking it to the purchase order and accounts payable system check; then generation can be stopped should a vendor fall out of compliance. Ultimately, finding a single solution that combines food safety records management and product tracking should be the goal.

Randy Fields is chairman and chief executive officer of Park City Group, a cloud-based software company that uses big data management for retailers and suppliers. Fields is a founding collaborator in ReposiTrak, an Internet-based solution for management of supply chain records. He can be reached at randy@parkcitygroup.com.


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