Overcoming the Adversity in Compliance with FSMA 204
As companies work on complying with FSMA 204 the biggest challenge by far has been nut butters. Any professional focusing on this one ingredient type has quickly come to the conclusion that this is no small project. Should you throw in the towel? Tell your company to stop carrying nut butters? Or, how can companies reasonably comply?
Here are some steps to help your company begin taking steps to understand where nut butters may appear in your products.
First, create a company communication to your supplier community asking for them to self-identify which of their products is on the Food Traceability List (“FTL”) and subject to FSMA 204. For your materials, this is incredibility important. Include links to the FDA website providing details on the FTL so they can easily research this if they are not currently aware. Here is the link.
Second, create an internal company communication to all stakeholders alerting them to FSMA 204 and the products and categories on the FTL list and ask them to help you identify your products that are subject to FSMA 204. While you may presume to know that answer, ask the question and confirm it anyways. Nut butters can be in flavors and other seemingly insignificant ingredients. The more people that are typically involved in creating a product specification, the more should be involved in identifying any ingredient (especially nut butters) subject to FSMA 204.
Next, create a company list of ingredients and finished goods that are subject to FSMA and publish it with a publish date. Share that list with all internal stakeholders and ask them to review it and confirm the list is complete. Include all pertinent information, such as item# / SKU # and related information. For materials, you may want to add the supplier (s) that are providing you the product.
After that, and once the list is confirmed, begin outlining your traceability plan for the products identified. Keep in mind that you can have one plan for all ingredients but you need to identify each ingredient. If there are different processes for your ingredients, this should be outlined in your traceability plan.
Now that the list is confirmed and you have begun your traceability plan, the selected materials and finished goods items should be discussed with your solution provider so they can assist you with the data collection needed at receiving, product creation, and / or shipping.
For more information on working with Share-ify for your FSMA 204 compliance needs, please contact us at [email protected].
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