Is there a way processors can ensure food safety management systems will meet the final FSMA regulations? There is no guarantee, but some programs will increase your odds.
It is been interesting to see how the new law and regulations have been described. HACCP on steroids and a contention that HACCP is a reactive program whereas HARPC is proactive are among my personal favorites. The latter is rather amusing since it’s been over 20 years since Former FDA Commissioner David Kessler praised HACCP as being proactive.
The most important point in FSMA is that it mandates all processors develop, document, implement and maintain a food safety plan or, even better, a food safety management system. Even though this is now a mandatory requirement, I wonder how many companies have not implemented such systems.