Following the proposal of two new food safety rules by the U.S. Food and Drug Administration (FDA) on January 4, 2013, Hogan Lovells US LLP of Washington, D.C., recently issued memorandums that overview each proposed rule. Each memorandum provides key take-aways for those companies that will subsequently be affected. The FDA proposed rules address preventive controls for human food and produce safety, each highlighting the Food Safety Modernization Act’s (FSMA) chief effort to shift the food safety focus from reactive to preventive.
Highlighted in this post is Hogan Lovells’ memorandum that overviews the preventive controls proposed rule, or more specifically, the “Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventive Controls for Human Food.” Hogan Lovells later released their memorandum on the second FDA proposed rule, produce safety.
Of the ten key take-aways listed in the January 9th preventive controls memorandum, GFSI (Global Food Safety Initiative) and the SQF Institute are specifically mentioned. The fourth key take-away of the memorandum, Testing and Supplier Verification, describes an Appendix of the FDA proposed rule that further details the agency’s desired testing and supplier verification activities, in which the memorandum notes, “FDA cites the Global Food Safety Initiative (GFSI) framework, and GFSI recognized certification schemes such as Safe Quality Food (SQF) 2000, as a valuable tool for supplier verification.”
To view the entire memorandum issued by Hogan Lovells, click here.
To view the pages of FDA’s preventive control proposed rule in which GFSI and SQF are described, click here.