Like a lot of you, I’ve been thinking a lot recently about the Food Safety and Modernization Act.
There are a couple of reasons for this. The first is that I’m still relatively new to the industry, and it’s a big change, so I’ve been trying to get up to speed on exactly what it does — and doesn’t — require. The other is that we had a new administration take over in January, and that always adds an element of the unknown to rules and regulations at the federal level.
But what I’ve been thinking the most about is a common theme that has come up as I’ve reported on different stories over the last few months: FSMA won’t actually have that big of an impact on large manufacturers.
Sure, it’s a new standard, and there are things that even large manufacturers will probably have to adapt to, even if they’re at the margins. But in a lot of cases, those manufacturers are already exceeding what FSMA requires, often because their customers require them to.
Smaller specialty manufacturers may already be exceeding FSMA as well, because they may be selling to boutique or upscale grocery stores or distributors that have higher standards for things such as food safety controls or allergen control.
Which brings me back to what I’ve been thinking the most about: What will FSMA actually mean, and to whom will it mean it?
The short answer is “it depends,” which is unsatisfying but logical. If you’re a granola bar manufacturer in Arizona, your answer might be different from a seafood processor in Maine. If all you make is frozen orange juice, you’ll have a different answer from a company that makes both frozen OJ and ice cream.
The longer, more thought-out answer is … well, “it depends.”
The reason it depends is that like other regulations, FSMA is a floor and not a ceiling. It doesn’t say “you have to do exactly this”; it says “you have to do at least this.” So some companies will do the minimum — which isn’t intended as a criticism — some companies will go a little above and beyond, and other companies will go well above and beyond.
We see this in other regulations, of course, and most of them are generally accepted as the cost of doing business. With existing regulations, processors have the advantage of knowing what to do and how to do it to be in compliance, which goes a long way toward changing the perception of a regulation from extra work to a valuable safeguard. But when a new one comes along, it’s easy to fall into the mindset of thinking “oh great, this new thing is going to be a headache.”
But we adapt, and sometimes that process is more painful than it is at other times. But as long as the end result is a healthier, safety food supply, then hopefully all the headaches will be worth it.
Will it? Well … I guess that depends.