How Proposed FSMA Changes Could Affect The Cold Chain

By Melissa Lind, contributing writer

The latest round of proposed additions to FSMA has the potential to significantly impact the food supply chain. However, they are having minimal effect on traceability. While many food managers may dismiss the changes as inconsequential, they shouldn’t breathe a sigh of relief yet as they may ultimately feel a pinch.

The most significant impacts in the latest FMSA proposals are in the areas of raw manure use and water-quality testing for produce growers. While this may not seem like it becomes an issue for the cold-chain industry, it may have consequences in terms of cost.

Water-Quality Testing
The newly proposed FSMA changes would allow for a step-wise approach to testing based on the actual risk of contamination. Farmers whose water supply does not meet standards for microbial contamination will have more options for improvement to meet the limits. Included within is water to harvest delay or a harvest to final storage calculation.

Raw Manure Use
The FDA initially proposed a mandatory delay of 9 months before crops treated with raw manure could be harvested. This was accompanied by a 45 day wait for compost application to harvest, but the agency is reconsidering the issue and delaying a final decision. This delay will allow farmers to continue current use of raw manure. However, the FDA is advising that the USDA’s National Organic Program manure use rules of a 90 day wait for non-ground contact crops or 120 days for crops in contact with the soil be followed. Additionally, it has been proposed that composted material is used in place of raw manure.

A final decision on the timeline is not expected for five to ten years as the FDA will be conducting studies and performing risk assessments regarding industry requirements to convert farming methods away from manure use to compost use. The primary driver behind both of these initiatives is to reassure the public that possible contamination of produce is minimal. Converting fertilization- and water-quality methods can be costly. They also require waiting periods and increasing the complexity of testing can slow down production.

In addition to the agricultural changes proposed, more-extensive testing is also proposed for products and facilities for both animal and human foods. Some corporations have already implemented similar methods, but the greater impact may be seen on smaller farmers, particularly local and organic farmers.

While the additional regulations appear at first glance to affect mainly agricultural producers, there is a domino effect on the cold-chain industry. Changes cost money — and the increased cost may be passed down to distributors. Additional time spent by producers in meeting regulations may result in distribution delays and unhappy customers. Some cold chain warehouses may also have to adjust internal processes to assist in the documentation of the producers becoming and remaining compliant. Ultimately, it isn’t just the producers reputation or business on the line, it is everyone involved in the supply chain.

Disruptions, recalls, and loss of consumer confidence cost money, so it is imperative that cold-chain participants act proactively to assist up-line suppliers in data exchange and act as partners as much as possible to ensure the safest and most cost-effective way to deliver goods from harvest to table.