“Domestically, FDA has historically leveraged a partnership with the states to reduce its workload, and you can expect this to continue and, most likely grow,” says Acheson. One program that exemplifies this idea is the state cooperative program for Grade A dairy facilities. With this program, state inspectors visit dairies—not the FDA. While this program works for dairies, it will present some challenges for other food categories, especially in creating a set of uniform standards and training, according to Acheson.

While FDA has traditionally not made much use of other Federal agencies for sharing inspection responsibilities, funding issues and FSMA will drive Federal partnerships, for example, the Agricultural Marketing Services. AMS inspectors already have a presence on farms, and the AMS can be expected to step up to the plate and become more involved with product standards, especially in produce, says Acheson.

The regulation allowing third-party auditors to be accredited by FDA to issue food import certifications is a new provision established by FSMA. The use of third-party auditors is not new, and Acheson notes that adherence to international standards like GFSI, BRC, SQF and FSSC2200 will increase the need for third-party auditors.

Foreign governments can also play a role in ensuring food safety, but according to Acheson, “while it is clearly desirable to both shift the burden and share the cost of inspections with foreign governments, FDA will not find this to be easy.” Determining which governments have comparable systems will be key to understanding what can be expected from these governments.

Dr. David Acheson serves as the managing director of the food and import safety practice at Leavitt Partners. Prior to joining Leavitt Partners, Acheson served as associate commissioner of foods at FDA.

To read the entire blog by Acheson, visit the Leavitt Partners blog site.