As the saying goes: “Image is everything.” So, most small businesses, as defined by revenues, have a tendency to refer to themselves in term of projected future revenue growth. However, sometimes it pays to be realistic and be firmly planted in the present. This is the case with FSMA (Food Safety Modernization Act) compliance.
No doubt, you have big dreams. However, when it comes to Good Manufacturing Practices, it pays to be small as defined by the government. According to the US CFR (Code of Federal Regulations),a very small business is defined as one having yearly revenues of $2.5MM, or less; a small business has less than 500 full-time employees, regardless of annual revenues.
With these definitions in mind, FSMA compliance requires that very small businesses document and implement current Good Manufacturing Practices (cGMP) by September 17, 2018; while small pet food manufacturers (those with more than 500 employees) needed to do so by September 18th of this year (2017).
So, as a “very small business” you have an additional year (i.e., until September 17, 2019), to document your hazard analysis and risk-based preventive control measures; small manufacturers have until September 2018.
If you are co-packed and don’t actually manufacture your food directly, you will still be required to have procedures in place. These procedures will include many provisions for communication with your co-packer. However, legally, you will ultimately be responsible for the product you provide to the consumer. Therefore, you will still need to develop your own cGMPs.
In the meantime, your trade association, Next Gen PFMA is drafting an outline of steps to take to meet cGMP conditions. This document will be available for free to members.
How can we help you succeed in the new era of FSMA law? We are here to serve your needs.
Sometimes, Small is Good
