There are known knowns and known unknowns, the existentialist Donald Rumsfeld once mused. Count the Food Safety Modernization Act of 2011 (FSMA) among the known unknowns.
FSMA’s first anniversary arrived January 4 this year, and while FDA staffers have made progress in laying the implementation foundation and tightened controls over imported foods and raw materials, requirements for food and beverage manufacturers are hazy at best. Proposed rules for “preventive controls”—FDA speak for a hazard analysis, critical control points (HACCP) plan—likely won’t be unveiled until February or March, and experts predict tighter plant security requirements won’t be known until 2013. In the meantime, production executives and food safety specialists are reviewing their existing HACCP programs and probing for gaps that might surface when FDA auditors begin conducting their own inspections.