IFT Reflections: Understanding FSMA and How it Relates to Campylobacter

With the implementation of the Food Safety Modernization Act of 2011 (FSMA), food safety practices are undergoing their largest re-haul since the Food, Drug and Cosmetic Act of 19381.  FSMA has provided much needed updates to food safety practices, an emphasis on traceability, and a large focus on produce.  However, FSMA will change the farming and food industry as a whole.  The poultry industry, where most of the Kathariou Lab’s Campylobacter isolates come from, may also be effected.  To understand how FSMA will affect the poultry industry one has to understand FSMA.  It is also important to keep in mind that meat, poultry, and eggs are covered under the USDA so FSMA (which effects the FDA) will not effect them directly.  However, the effects of FSMA will ripple into all parts of the food industry so these kinds of changes might take place in the USDA several years down the road.

FSMA is broken up into 4 titles, or sections, that outline the new standards and rules set for several different food products and facilities.

Title I: Improving the Capacity to Prevent Food Safety Problems

The first title deals with new pre- and post-harvest standards for produce, improving food defense, and implementing HARP-C (Hazard Analysis and Risk-Based Preventative Controls) for produce.  This is the section that deals heavily with the Produce Rule, which was finalized in 2015 and provides detailed guidance on water, soil, and other practices used in the produce industry.

Title II: Improving the Capacity to Detect and Respond to Food Safety Problems

This title covers third party inspection verification, improved traceability of food products, and further discussed food defense.  This section also grants the FDA the power to perform a mandatory recall.  All recalls before now were voluntary and this provision marks a shift in power towards the FDA.

Title III: Improving the Safety of Imported Foods and Title IV: Miscellaneous Provisions

The third title gives new regulations and standards for foreign food process that import to the US must meet. The fourth title covers budgetary concerns, jurisdiction, and employee protection1.

But where does Campylobacter fit in all this?

Although Campylobacter isn’t only found in poultry (it can be found in raw milk and cross contaminations can place it on other products)2, it’s impact on the poultry sources of Campylobacter will be reviewed here.  (To learn more about how poultry processors deal with Campylobacter go here.) There are actually a couple places that Campylobacter fits in all the legal jargon of FSMA.  The increased traceability applies to all foods which means that producers will have to be more meticulous about record keeping and supply chain management.  Traceability applied to live animals with a relatively short life span, like poultry, will provide interesting challenges to producers as a whole.  FSMA is also championing more frequent inspections of processing plants, packers and farms by the government and third party entities.   Since not all third party entities have the same regulations and different buyers require different standards, preparing a facility to meet all the new standards will take time. The EU and other countries have a larger problem with Campylobacter than the US so foreign suppliers of poultry and other products known to harbor Campylobacter need to meet stricter guidelines and implement more stringent food safety plans1.

Along with the challenges, some regulations will be easy to implement.  Large poultry companies are often vertically integrated, which means they have control over every step in the process of rearing the animal3.  Not only is this practice cost effective, it lends itself to traceability in that the producer already knows where their supplies are coming from every time.  Most of the poultry consumed in the US is produced domestically, making Campylobacter from foreign products less of a concern4.

FSMA marks a change in the way the US handles food safety and a shift in what safe food means for consumers as a whole.  Every segment of the food industry will be effected.  However, this is not a comprehensive review of FSMA.  To read the full text of the law go here and to get a more comprehensive overview go here.

 

1 21 U.S.C. § 418. The Food Safety Modernization Act. 2011. http://www.fda.gov/Food/GuidanceRegulation/FSMA/ucm247548.htm#SEC108

2 CDC. Campylobacter. Jun 2013. http://www.cdc.gov/foodsafety/diseases/campylobacter/index.html

3 NCSU. The North Carolina Poultry Industry. North Carolina Cooperative Extension Service. 2007. https://www.ces.ncsu.edu/depts/poulsci/tech_manuals/poultry_industry.html

4 United States International Trade Commission.  Poultry: Industry and Trade Summary. Office of Industries. Jan 2014. https://www.usitc.gov/publications/332/poultry1.pdf