Food Safety Magazine, June/July 2011

• 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.

References

1. www.deloitte.com/assets/Dcom-UnitedStates/Local%20Assets/ Documents/Consumer%20Business/us_cp_2010FoodSurvey Results_050310.pdf. 2. www.deloitte.com/view/en_US/us/Industries/consumer-products/ 1912cf06d7c38210VgnVCM100000ba42f00aRCRD.htm. 3. www.marlerblog.com/lawyer-oped/william-d-marler-esquire---speech-before-the-house-of-lords-dinner---how-one-peanut-company-caused- 1. 4. www.fda.gov/AboutFDA/CentersOffices/OC/OfficeofFoods/ ucm211567.htm. 5. www.fda.gov/Food/FoodSafety/FoodSafetyPrograms/RFR/ ucm200958.htm#fig7.