President’s Report – Food Safety and Modernization Act Implementation
The Food Safety and Modernization Act (FSMA) was promulgated into law on January 4, 2011 with the goal of making our nation’s food supply safer. Over the course of the last three years certain portions of the legislation have been rolled out and implemented in different aspects of the agricultural supply chain. On January 26, 2018 the section that affects our Association and every other tree nut operation in our land was implemented.
Your Association has been very active in regards to the implementation of FSMA and has worked closely with Western Agricultural Processors Association (WAPA) an organization of which I am the current Chairman. Collectively, we have worked to make sure that FSMA is workable for the tree nut industry and not implemented with a command and control approach that would be a disservice to all stakeholders. To this end, I traveled to Washington, DC with WAPA President & CEO, Roger Isom and fellow Board members and staff in 2016. We went to lobby our congressional delegation and for direct discussions with the Food & Drug Administration in order to make those who implement the laws knowledgeable about our concerns. I am pleased to report that our concerns were heard and while FSMA is now the rule of the land, and implemented, we believe that the regulations as they pertain to almond Hullers and Shellers are attainable. Our Association is under the Produce Safety Rule and as such our portion of FSMA pertains to Good Manufacturing Practices, most of which we had already implemented. Over the last 14 years I have felt that due to our enormous size it was important to protect the Association’s members and our handlers from potential recall events. It made good sense!
I am so pleased that we have been able to transition to a smooth execution of FSMA because we were pro-active and did not wait for the regulations to come into force before we acted. As such, we were able to discuss with regulators and work with our friends at WAPA to affect change on components we felt were not necessary and implement those components our industry could embrace for the betterment of the food supply chain. To make sure we are documenting each and every requirement of FSMA we worked with Priscilla Rodriquez, the Director of Food Safety at WAPA. We shared advice and ideas in developing a step-by-step binder for our specific Food Safety Plan for Almond Hullers and Shellers. This document will be the first point of reference when FDA comes for inspections when the enforcement component of the Act is implemented in January 2019.