Complying with FDA's Training Requirements
FDA introduced training requirements into the Food Safety Modernization Act regulations.
FDA introduced training requirements into the Food Safety Modernization Act regulations.
Seemingly, the numbers of recalls being caused by Listeria Monocytogenes concerns is increasing. Over the last 24 months, for example, we have witnessed a lengthy series of food product recalls involving large amounts of products being contaminated at very low levels over long periods of time.
Some say that history continuously repeats itself. The evolution of pathogen control in our national food supply is no exception.
As we look back over the past several months, we see that allergens continue to upset the meat industry. Within the last year, there were dozens of recalls of meat products for the presence of undeclared allergens.
Producing meat products that are free from pathogens requires commitment and expertise. In turn, there are many standards that govern the types and frequency of sampling and testing that companies are required to perform within their facilities and on their products.
The production of safe food is one of the most challenging jobs in the world. All food producers, distributors and retailers are surrounded by risk. The key to protecting your brand is to avoid an outbreak or recall in the first instance.
As a food safety lawyer, I enjoy reviewing recall statistics to see how the food industry is doing overall at avoiding large-scale recalls.
When it comes to food production, the ultimate safety of the product you produce will typically only be as good as the quality of your training programs. Too often, when I work with clients who have world-class training programs, I hear them complain in frustration about how difficult it is to train their employees.
As a FDA and USDA lawyer serving the food industry for nearly two decades, I have witnessed substantial changes in the way that food safety is regulated by these two agencies. While some might describe the evolution as the maturation of food safety, others may refer to it as somewhat chaotic.
As a food safety lawyer, I have spent my fair share of time litigating foodborne illness claims. And, for as long as I can remember, whether debating with a mediator, a judge or a jury, there has been a lasting debate about whether the ultimate responsibility for protecting against pathogens in raw animal products rests with industry or the consumer.