FSMA Fridays: FSMA Compliance Implementation Challenges And Guidance (Part Three Of Four)

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In Part Two of FSMA Fridays: FSMA Compliance Implementation Challenges And Guidance, the Acheson Group’s Dr. Peyman Fatemi and Christopher Snabes spoke with SafetyChain’s Jill Bender about supply chain controls and FSMA’s relation to GFSI-certified food safety schemes. Here, in Part Three of the series, the trio will address finished product testing under FSMA.

Jill: Moving to our next topic: finished product testing. I believe, Peyman, you were going to address this. What are some of the challenges and guidance around that?

Peyman: I think that finished product testing, or really testing in general, fits nicely, and Chris alluded to that, within a hazard analysis and risk-based preventive control approach for FSMA. Finished product testing is really intended as a verification step to make sure that the preventive controls that you implemented — whether it used to be your CCPs or preventive controls — are indeed effective. It needs to be appropriate to the food, the risks that you’re trying to control, and the specific process.

It’s not a requirement, by looking at the strict definition of the rule, finished product testing is not a requirement, but it can be a component as a verification of preventive controls. It’s a very useful tool. Obviously there are a lot of questions in terms of how much to test, what to test for, how often to test, and these are all the questions that are being asked, and are the pertinent ones. It’s appropriate to the risk.

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