Defining A Foreseeable Hazard

A central tenet of the new food safety law is a responsbility for food manufacturers to thoroughly inspect their plant facilities to uncover “foreseeable hazards,” not otherwise defined.

Why is this important? We’ll, because over time, the Food and Drug Administration (FDA) has done enough plant inspections to understand that manyh food contamination incidents and recalls originate in production facilities, where harmful pathogens can lurk. It could be stagnant water, or the wrong spray lubricant on a bread pan, or a line worker with hepatitis.

Peanut ButterUnder the new law, acronym FSMA, manufacturers themselves must inspect their facilities, identify safety hazards, and then develop a food safety plan that includes step-by-step procedures to eliminate those hazards.

That’s a huge swing in the FDA’s regulatory philosophy. Heretofore, the agency focused on swift action after a food recall to limit consumer exposure. With FSMA, the emphasis is on preventive controls to eliminate safety risks before they fester into problems.

WIthout a doubt, managing food safety through preventive controls (and employee training) will be a costly new expense. The real concern of regulators and industry observers is not the major food brand, but the smaller-sized manufacturers.  Will they have the budget and the people to prevent contamination as an everyday management priority?

Only time will tell. But how that question is answered could make a difference in preventing food-borne illnesses or deaths.

More information on foreseeable hazards is here.


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