Websites: FDA Flashcards
(81 cards)
What is FDPB?
The Food Defense Plan Builder (FDPB) version 2.0 is a user-friendly tool designed by FDA to help owners and operators of a food facility in the development of a food defense plan that is specific to their facility and may assist them with meeting the requirements of the Mitigation Strategies to Prevent Food Against Intentional Adulteration regulation (21 CFR Part 121) (IA rule).
The Food Defense Plan Builder guides the user through the following sections:
Facility Information Product/Process Descriptions Vulnerability Assessments Mitigation Strategies Food Defense Monitoring Procedures Food Defense Corrective Actions Procedures Food Defense Verification Procedures Supporting Documents Food Defense Plan Signatures
What is the aim of the FDA Food Safety Modernization Act (FSMA)
The FDA Food Safety Modernization Act (FSMA) final rule is aimed at preventing intentional adulteration from acts intended to cause wide-scale harm to public health, including acts of terrorism targeting the food supply.
[Such acts, while not likely to occur, could cause illness, death, economic disruption of the food supply absent mitigation strategies.]
FDA Food Safety Modernization Act (FSMA) strategies (broadly speaking)
Rather than targeting specific foods or hazards, this rule requires mitigation (risk-reducing) strategies for processes in certain registered food facilities.
When was the FDA Food Safety Modernization Act (FSMA) issued?
The proposed rule was issued in December 2013.
Who is covered by the FDA Food Safety Modernization Act (FSMA)
With some exceptions, this rule applies to both domestic and foreign companies that are required to register with the FDA as food facilities under the Federal Food, Drug, and Cosmetic (FD&C) Act.
This rule is designed to primarily cover large companies whose products reach many people, exempting smaller companies. There are 3,400 covered firms that operate 9,800 food facilities.
It does not cover farms.
Key provisions of the FDA FSMA
Companies are required to prepare and implement a food defense plan. This written plan must identify vulnerabilities and actionable process steps, mitigation strategies, and procedures for food defense monitoring, corrective actions and verification. A reanalysis is required every three years or when certain criteria are met, including mitigation strategies that are determined to be improperly implemented.
Vulnerability assessment: This is the identification of vulnerabilities and actionable process steps for each type of food manufactured, processed, packed or held at the food facility. For each point, step, or procedure in the facility’s process, these elements must be evaluated:
- -> The severity and scale of the potential impact on public health. This would include such considerations as the volume of product, the number of servings, the number of exposures, how fast the food moves through the distribution system, potential agents of concern and the infectious/lethal dose of each; and the possible number of illnesses and deaths.
- -> The degree of physical access to the product. Things to be considered would include the presence of such physical barriers as gates, railings, doors, lids, seals and shields.
- -> The ability to successfully contaminate the product.
Mitigation strategies: These should be identified and implemented at each actionable process step to provide assurances that vulnerabilities will be minimized or prevented.
Monitoring: Establishing and implementing procedures, including the frequency with which they are to be performed, for monitoring the mitigation strategies.
Corrective actions: The response if mitigation strategies are not properly implemented.
Verification: Verification activities would ensure that monitoring is being conducted and appropriate decisions about corrective actions are being made.
Training and recordkeeping: Facilities must ensure that personnel assigned to the vulnerable areas receive appropriate training; facilities must maintain records for food defense monitoring, corrective actions, and verification activities.
Compliance date for the FDA FSMA
Very Small Businesses— (< $10,000,000, per year): five years after the publication of the final rule.
Small Businesses—(< 500 employees) would have to comply four years after the publication of the final rule.
Other Businesses—would have to comply three years after the publication of the final rule.
Exceptions FDA FSMA
- A very small business.
- The holding of food, except the holding of food in liquid storage tanks.
- The packing, re-packing, labeling or re-labeling of food where the container that directly contacts the food remains intact
- Activities that fall within the definition of “farm”
- Manufacturing, processing, packing, or holding of food for animals
- Alcoholic beverages under certain conditions
- On-farm manufacturing, processing, packing, or holding by a small or very small business of certain foods identified as having low-risk production practices. The exemption applies if such activities are the only activities conducted by the business subject to the rule. These foods include certain types of eggs, and certain types of game meats.
What is the NACMCF?
National Advisory Committee on Microbiological Criteria for Foods (NACMCF) is an advisory committee chartered under the U.S. Department of Agriculture (USDA)
Participants in the NACMCF
The National Advisory Committee on Microbiological Criteria for Foods (NACMCF) is comprised of participants from the:
- USDA (Food Safety and Inspection Service),
- Department of Health and Human Services (U.S. Food and Drug Administration and the Centers for Disease Control and Prevention)
- the Department of Commerce (National Marine Fisheries Service),
- the Department of Defense (Office of the Army Surgeon General),
- academia, industry and state employees.
What is a CCP Decision Tree?
A sequence of questions to assist in determining whether a control point is a CCP.
HACCP: Control
(a) To manage the conditions of an operation to maintain compliance with established criteria.
(b) The state where correct procedures are being followed and criteria are being met.
Control Measure:
Any action or activity that can be used to prevent, eliminate or reduce a significant hazard.
Control Point:
Any step at which biological, chemical, or physical factors can be controlled.
Corrective Action:
Procedures followed when a deviation occurs.
Criterion:
A requirement on which a judgement or decision can be based.
Critical Control Point:
A step at which control can be applied and is essential to prevent or eliminate a food safety hazard or reduce it to an acceptable level.
Critical Limit:
A maximum and/or minimum value to which a biological, chemical or physical parameter must be controlled at a CCP to prevent, eliminate or reduce to an acceptable level the occurrence of a food safety hazard.
Deviation in HACCP:
Failure to meet a critical limit.
HACCP Plan:
The written document which is based upon the principles of HACCP and which delineates the procedures to be followed.
Hazard:
A biological, chemical, or physical agent that is reasonably likely to cause illness or injury in the absence of its control.
Hazard Analysis:
The process of collecting and evaluating information on hazards associated with the food under consideration to decide which are significant and must be addressed in the HACCP plan.
Monitoring:
To conduct a planned sequence of observations or measurements to assess whether a CCP is under control and to produce an accurate record for future use in verification.