Shifting focus
Food safety is in no way new to bakeries. The industry has always been working to protect people from accidental contamination. No company wants its consumers to get sick from eating its food. The name of the food security game today is all about prevention.
“FSMA changed the food protection responsibility in many ways,” said Gale Prince, president of Sage Food Safety Consultants. “It shifted the responsibility for the industry to be more involved in preventing product contamination instead of responding after the fact.”
While many protections and strategies have been put in place to protect against accidents — sanitation standards, hairnets, gloves, no jewelry — FSMA is moving the focus away from accidents and toward scenarios where individuals are intentionally trying to cause harm.
“Under the old food safety rules, the Food and Drug Administration (F.D.A.) and U.S. Department of Agriculture (U.S.D.A.) had regulations to control the normal accidental contamination that would happen from insects or getting delivered the wrong product,” Mr. Carr said. “What FSMSA focuses on is preventing intentional contamination, so now you’re really into a different realm. Now you’re trying to stop people from trying to cause you harm.”
As the industry makes this shift, FSMA leaves much of the detail up to the bakery. While previous guidance from the F.D.A. has been more direct, like dictating the use of non-flaking paint, Section 106 only requires that bakeries be able to show that they have effective and reasonable controls, training and record-keeping.
“What’s reasonable and effective is very dependent on your situation, so it’s hard for the F.D.A. to determine that,” Mr. Heflich said about the vagueness of the law. “But it would be perfectly reasonable to expect that you would have some kind of program in place, that you’ve trained your employees, that you’ve got some documentation and you’ve got some controls and checks in place to detect failure. That’s what FSMA is asking for.”
With the exact details of their plans left up to each individual bakery, it can be intimidating to get started. For new bakeries, a conversation with a design and engineering firm about security can be enlightening.
“During the design development phase, once we get basic planning and programming in place, we’ll have the security conversation,” said John Koury, architect consultant for AM King. During this conversation, Mr. Koury discusses the bakery entrances for management, employees and visitors as well as how the plant will control access to various vulnerable places.
In existing bakeries, a risk assessment of the facility is a good place to start. When Bimbo Bakeries USA (B.B.U.) began looking at the security of its plants 10 years ago, the company started by evaluating its individual facilities. B.B.U recognized that each one’s needs would be different. “Based on the risk assessments, we have customized our plans and programs by bakery because each bakery is different,” explained Arturo Carrillo, director of food safety, B.B.U. “Once we defined the sensitive areas, we defined the procedures and actions necessary to make them secure.”
Often these susceptible places are centered around the facility itself or the people entering it.
