FDA Released a Food Safety Plan Builder Tool – DO NOT USE THIS!
A few weeks ago the FDA released a software tool to build a Food Safety Plan. This tool is built to guide users through a process to demonstrate compliance with the HUMAN food rule (21 CFR 117)! This is very different from 21 CFR 507, the Animal Food Rule. I have heard that some inspectors are recommending this tool. Thank them for the information but tell them “this tool is not built for the animal food rule and that is what I need to comply with”. I am not aware that a similar tool is being built for Animal Food. If I hear of one, I will let my readers know.
Animal Food Inspections in New York
A student in the August FSPCA Preventive Controls for Animal Food course held at Cornell University recounted his experience with a visit from an FDA Inspector a few weeks earlier. The feed mill is owned by a corporation in California and was on a list of 14 large New York State facilities the inspector would visit over a 6 month period. After a short discussion and confirming with the Corporate Office that the company had less than 500 employees the inspector left. The discussion focused on the company knowledge of FSMA and work towards compliance with CGMP’s. This inspector did exactly what the FDA has been saying they will do “educate while they regulate”.
September 18th is the next FSMA deadline
In just 22 days the compliance date for animal food facilities with less than 500 employees but larger than a very small business are required to have a training program and CGMP’s in place. There is only one documentation REQUIREMENT in this phase and that the documentation of your personnel hygiene policy and training for Qualified Individuals. As discussed above, the inspections of large firms (with a compliance date of September 19, 2016) is progressing but at a slow pace. It is not expected that smaller facilities will be inspected in the next few months.
Note: The delay announced last month was only a delay in inspections of large companies for their compliance with Hazard Analysis and Preventive Controls portion of the rule. Large businesses need to comply with this by September 18, 2017 but inspections will not occur for at least a year.
FSPCA Preventive Controls for Animal Food 2018 Course Schedule
The course schedule for 2018 has been posting on the training page. Classes will be held at Cornell in March and December. Additional classes may be scheduled as we work with New York State Department of Ag and Markets to access the need for inspector training. These classes will likely be held at state office building locations. Watch the training page for opportunities.