Like every modern industrial sector, the food processing sector has seen dramatic changes over the past few years. Not only has the sector seen a consolidation of large operators and retailers impacting balance of power and profit margins, but now rapid changes in food safety compliance. The Food Safety Modernization Act (FSMA), signed in 2011, is now coming into effect for many processors. Your organization may have addressed the documentation and control compliance work, but is your ERP capable of following through with the processes developed? ERP system implementation is time consuming and costly, but organizations must address the question “how much will a failed recall cost?”
Here are 4 major points to consider above and beyond the new conceptual regulatory requirements.
- The old days when the FDA could only request a product recall are over. The FDA can now demand recalls as well as close production plants while investigations are performed. Being unable to quickly and adequately respond to FDA audits could be catastrophic. Your organization, of course, has adequate documentation about procedures and controls, but is your ERP system capable of meeting the FDA’s requirement to provide all necessary tracking information within four hours?
- Has your procedure documentation been tested? Many processors that are supplying national retail chains are required to perform mock recalls on a quarterly basis. Often there is a gap between the theoretical procedures and what systems are capable of performing. This is a good exercise to ensure any system deficiencies are identified and dealt with, because failing a mock recall can be as devastating as a real recall if the retail partner decides to switch suppliers.
- Your system must do more than merely tracking where your product started and where it ended. Review your system to ensure it is capable of tracking details such as how raw materials arrived, what temperatures they are stored at, time in storage, QC inspectors, operating personnel involved in manufacturing and distribution and key people responsible for safety and security of the final product. Your system must be capable of tracking these details and more.
- The new Bioterrorism Act requires processors to maintain a record of all inputs used to produce a product. For products intended for human consumption, the processor must track the source information for all ingredients contained in the product. For all ingredients received, the processor must be able to identify all intermediate and finished products for which the ingredients were used.
FSMA is completely changing the regulatory requirements for any processor wishing to access the American market. A well designed ERP system is an invaluable tool to help support an organization during stressful times.