Countless resources (including financial) have gone into developing both training programs and skilled professionals to strengthen the safety of our food supply.
While all food manufacturers have faced great challenges in this sweeping set of rule
changes, none have faced more uncertainty, and been more challenged, than those
that operate as small and very small food businesses. These businesses tend to be
primarily owner operated, working with a lean staff (fewer than five) and unable to
dedicate anyone to work solely on FSMA compliance.
There are often two scenarios behind a lack-of-resources issue: financial and
workforce. A company that lacks financial resources will be unable to support a food
safety and quality professional. They may not be able to provide the necessary training to ensure that they know the applicable laws. A company with a lack of workforce resources will have personnel that know about the laws, but these people are
tied up in “firefighting” activities and have no time to plan for the future or dedicate
time, energy and mental capacity to developing or updating the necessary programs
to ensure FSMA compliance.
Working closely with manufacturers of
all sizes, we have witnessed smaller manufacturers face a herculean task to grasp and
understand the new FSMA rules. They
struggle with understanding whether they are exempt from certain parts of the rules
and if so, which ones. Many states have attempted to address this by providing
lower-cost training for Preventive Controls-Qualified Individual (PCQI) certificate
courses. The Ohio Department of Agriculture invested in Lead Instructor training
for several of their food safety team members. This has allowed them to offer Food
Safety Preventive Controls Alliance (FSPCA) PCQI courses to small and very small
businesses for less than half the average going rate. Additionally, many industry organizations like the American Frozen Food Association invested in staff becoming
Lead Instructors of PCQI, offering a highly discounted rate to their members. While
this is very helpful for small businesses watching their budgets, the work of creating
the food safety plan continues to be seen and experienced as a monumental task for
small and very small food companies. So, these very small businesses look to others
for additional support in determining how to build a food safety plan that fits their
Small and very small food businesses have been seeking consultants for guidance
on FSMA compliance efforts. Consultants who are properly trained and proficient
with the FSMA rules come with a price that many small and very small companies
just can’t afford, so they look for alternative solutions. Too often, these companies
are misled into relying on consultants who may not be as experienced or as informed as they need to be regarding the implementation of the new FSMA rules.
Some consultants still mistakenly take the approach of writing Hazard Analysis and
Critical Control Points (HACCP) plans or Hazard Analyses and Risk-Based Preventive Controls for small food businesses after meeting with them for a day or less.
Some will even write a full food safety plan for a company after a short phone call.
A one-size-fits-all approach may be offered with general product templates being
used to create these plans. Overworked and time-short managers/owners of small
and very small food businesses find these “low cost” plans hard to resist. Even worse
are those situations when the consultant will simply write an HACCP plan for the
company from a template without spending any time with the manufacturer.
Say What You Do
Developing a food safety plan is a process that requires the involvement of the
key people in the food business and takes more than a day to review and develop
accurately. Not only do small businesses usually fail to implement the food safety
plans created by someone else, but
those plans often do not reflect the real
practices of the food manufacturer and
fail to keep the products safe or meet
regulatory requirements. This has cre-
ated a unique challenge for small and
very small food businesses that want
to do the right thing and be compliant
with FSMA but are not sure where to
turn for support.
There are several not-for-profit organizations dedicated to working with
and supporting the success of small
and very small businesses in the United
States. These organizations range from
independent to local, state and federally
funded entities. According to the National Institute of Standards and Technology,1 the Manufacturing Extension
Partnership (MEP) is a national system
of centers located in all 50 states and
Puerto Rico. Each center is a partnership
between the federal government and
a variety of public or private entities,
including state, university and nonprofit
organizations. This diverse network,
with nearly 600 service locations, has
close to 1,300 field staff serving as trusted advisers and technical experts who
are ready and able to assist small and
midsize manufacturing companies.
MEP centers tailor services to meet
critical needs, ranging from process
improvement and workforce development to specialized business practices,
including supply chain integration, innovation and technology transfer. The
MEP’s foundation is its partnerships.
Centers are the hub for manufacturers,
connecting them with government agencies, trade associations, universities and
research laboratories, state and federal
initiatives, and a host of other resources
to help them grow and innovate.
MEP centers have assisted over 25,000
manufacturers supporting the made-in-your-state and made-in-the-USA effort
“A lack of awareness is one of the greatest
challenges to FSMA compliance for many companies.”