The U.S. food industry recently helped pass the most sweeping food safety reform in half a century - the FDA Food Safety Modernization Act. Now that companies must comply with new legal requirements, understanding the implementation process is critical.
“We realize the complexity of this legislation. There are so many moving parts that have to fit together, and we realize how this is going to affect such a diverse sector of the economy,” said Michael Taylor, deputy commissioner of foods, U.S. Food and Drug Administration. “As arduous and suspenseful as getting the law passed turned out to be, implementation is going to be more difficult and take even longer.”
Joseph Levitt, partner at Hogan Lovells U.S., urged companies to prepare for the new requirements.
“This law is fundamentally a good law,” said Levitt. “It is something that is and should be embraced by the food industry, and it will ultimately enhance the safety of the food supply. The biggest danger any food company can place themselves in is to be complacent. Anyone who thinks they have always done a good job and that everything is going to be fine is making a mistake.”
Levitt also spoke on the importance of accountability under the new law. “This is going to be more like a tax audit than an FDA inspection,” he said. “They are going to know what you did, when you did it and how you reacted. They will want to see your corrective action files, they are going to want to see your HACCP plans, and they are going to want to see the justification for your HACCP plans.”
Taylor suggested that the best way to prepare for the upcoming implementation process is to work together.
“Partnership will be a theme of how we implement this law. GMA has been at the forefront of that with aligning a set of teams with the implementation teams at FDA, communicating at that team level and this is the information sharing that is going to make this work for all of us.”