The Best Way To Prepare For FSMA: Shred Your GMP Document
By Michael Kalish, Managing Member, Food Safety Guides
Too often, I see food processors, co-packers, and distributors composing food safety plans to meet what they presume an auditor or regulator would like to see. The result is a stilted food safety plan, checkered with redundancy and a variety of formats that make it awkward to teach, follow, and scale.
On August 30, the FDA will roll out its Final Preventive Control (PC) Rule, which will set new food safety standards for businesses manufacturing, processing, packing, and holding food. Businesses need to consider building systems that are friendlier for training their staff and more responsive. This means formatting programs to be:
- Shorter
- More Uniform
- More Flexible
This can be achieved with a simple shift in how we perceive “GMPs” and their relation to the food safety system — namely by redefining the role and importance of Standard Operating Procedures (SOPs) and Prerequisite Programs (PPs).
Standard Operating Procedures
Current Good Manufacturing Practices (cGMPs) are not “practices,” they are code. Think of them as 13 pages of food safety and quality goals. Goals don't dictate practices. Practices are directed by written SOPs.
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