• Assess or reassess facility risk, based on the criteria outlined
in the FSMA. Internal, as well as third-party facilities, both
domestic and foreign, should be included in the assessment
to fully understand the risks in the supply chain.
• Utilize subject matter specialists to characterize all products
and facilities as being high or low risk.
• Closely review regulatory enforcement actions taken in the
past 12 months for all facilities within the company, including subsidiaries and the effectiveness of the corrective actions implemented.
Value for the Company
The value of a thorough and regular review of all food safety
programs using internal and external subject matter specialists
can support the effectiveness of each part of the company’s
food safety system and will protect consumers as well as the
corporate brand. Such an approach may help companies more
quickly identify potential problems that could introduce a hazardous or non-compliant product into the marketplace. It may
also enable the organization to prevent personal injury to the
consumer; ward off subsequent regulatory, criminal and civil
litigation; avert costly mediation; protect the organization’s
brand image; and—ultimately—instill consumer confidence in
the safety of the company’s product line. n
Pat Conroy is vice chairman and U.S. Consumer Products leader
at Deloitte LLP.
Frank Oehl is a partner and the U.S. Food & Product Safety
lead for Deloitte & Touche LLP.
Craig Henry, Ph.D., is a director in the U.S. Food & Product
Safety practice of Deloitte & Touche LLP.
This article contains general information only and Deloitte is not
rendering professional advice or services. In addition, this article contains the results of a survey conducted by Deloitte. The information obtained was not validated or confirmed by Deloitte. Deloitte, its affiliates
and related entities shall not be responsible for any loss sustained by any
person who relies on this article.
2. www.deloitte.com/view/en_US/us/Industries/consumer-products/ 1912cf06d7c38210VgnVCM100000ba42f00aRCRD.htm.
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