“It’s all about brand protection,” said Don Hsieh, director of commercial and industrial marketing with ADT Security Services, and the leading expert on FSMA for the firm’s food defense program. He stressed that while companies need to ensure they are in compliance with the law, the most important element of compliance is protecting their brands.
Already unveiled is a focus on better food and ingredient tracing under FSMA, with the Food and Drug Administration (FDA) and the Institute of Food Technologists (IFT) developing two product tracing pilot programs under the new law.
“[Government authorities] will be wanting to ensure companies can track and trace,” Hsieh said. “…They may not say that companies have to use particular technologies but companies may want to look at GPS, for example, and other technologies to allow more real time tracking”
Often companies only track goods at certain contact points, such as when an ingredient leaves a warehouse and when it arrives at the manufacturing plant, for example. But with hundreds of thousands of food facilities and millions of trucks on the road, Hsieh said that manufacturers may want to have more information about where ingredients are on each stage of their journey.
“The real key is do they have the intelligence to act on the information? The thing that’s striking about the food industry is how large and long the supply chain is…If you look at that there are a lot of points of vulnerability. So companies need to ask, how can I protect myself?”
He said that there might be some very specific changes required under FSMA, such as specific documentation, so much of what the government will be looking for in terms of compliance could be focused on verification.
For example, food manufacturers generally do a good job of controlling certain sensitive areas for employee-only access, but they may need to ensure these controls are in place along the entire supply chain, he said. And imported food is also likely to be a focus area of FSMA, so supplier verification is an increasingly important consideration, whether carried out by manufacturers’ own employees, or by third-party auditors.
“I don’t think the government will be prescriptive in terms of the types of technologies companies use,” he said. “…The important thing is that it has elevated the importance of food safety, but the specific guidelines are still being rolled out. We are in a preparation phase.”