Taking on the FSMA Beast?

Posted by Stacey Drosner Murphy on Jan 31, 2018 2:16:59 PM

Ready to venture out now that spring is (hopefully) just around the corner?  Join us in March for our first 2018 Cherney College course, Preventive Controls for Animal Food. This course is the FDA-recognized training for pet food and animal feed companies that will comply with new FSMA regulations this year. We have been actively involved in FSMA training since 2016, training over 125 Preventive Controls Qualified Individuals or PCQIs. In our experience, FSMA for human food is a matter of tweaking and adjusting programs that are already in place. The experience for those in the animal food industry is a whole other beast (see what I did there?). For years, regulation at the state and federal level covered medicated feed, labeling and adulteration but now the industry will have to create programs to comply with current Good Manufacturing Programs (CGMPs) AND preventive controls. This is a lot to tackle in a short time!

Here are some of the challenges we’ve seen companies face as they go through this transition.

  • Understanding the new regulation (21 CFR 507) and how it fits with existing regulations (medicated feed, FDA human food, USDA, state)
  • Completing and documenting training, especially for PCQIs
  • Putting CGMPs in place based on risk
  • Going beyond HACCP to complete a FSMA-compliant hazard analysis that considers all preventive controls
  • Navigating the supply chain program for ingredients, raw materials and packaging

The good news is that you’re not alone! There are many resources available to help you on your FSMA journey. Our course in March could be your first step towards achieving compliance or if you’re already well on your way, the course will cross PCQI training off your to-do list. Compliance dates are fast approaching and regulatory activity is increasing already this year. FDA is targeted to conduct at least 500 animal food CGMP inspections by September 2018 and will start inspecting large companies (>500 employees) for preventive controls in the fall. Not sure when you need to comply?

Business Size

CGMP compliance date

Preventive controls compliance date

Business other than small and very small (>500 employees)

Sep 19, 2016

Sep 18, 2017

Small business  (fewer than 500 employees)

Sep 18, 2017

Sep 17, 2018

Very small business (a business averaging less than $2,500,000, adjusted for inflation, per year, during the 3-year period preceding the applicable calendar year in sales of animal food plus the market value of animal food manufactured, processed, packed, or held without sale)

Sep 17, 2018

Sep 17, 2019, except for records to support status as very small business (Jan. 1, 2017)

Want more information or to talk through your implementation plan?  Contact us at training@cherneymicro.com, sign up for our upcoming course below or call us at 920-406-8300. We’ll help you tame the FSMA beast!
FSPCA Registration

Topics: Cherney College, FSPCA, PQCI, FSMA Compliance, External Training, continuous improvement