A current state analysis of preventive control requirements and traceability infrastructure in small U.S. food facilities
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In 2011, the U.S. government enacted the Food Safety Modernization Act (FSMA). The goal of the new legislation was to reduce the 48 million people per year in the U.S. who are affected by food borne illnesses through the requirement of preventive controls in food supply chains. Compliance dates for small food businesses started in 2017, when the new preventive control measures were required to be implemented. This research focuses on understanding the current state of FSMA preventive control requirements in relationship to small food facilities. Also, an assessment of the traceability infrastructure within small food facilities was performed. A questionnaire based survey was developed from using the FDA’s FSMA Final Rule for Preventive Controls for Human Food and Animal Food along with the Institute of Food Technologist pilot study for FSMA traceability. The questionnaire was distributed to small food facilities in the state of Iowa. Fourteen different factors were analyzed from the questionnaire data: (i) food allergen controls, (ii) verification activities, (iii) current good manufacturing practices, (iv) food safety plan, (v) training records (vi) standard operating procedures, (vii) hazard analysis, (viii) recall plan, (ix) preventive controlled qualified individual, (x) operational control, (xi) accounting programs, (xii) inventory records, (xiii) lot coding, (xiv) business management software. Results were compared against the type of manufacturing, the size of the company, and how many years the company has been in business. A significant factor affecting the adoption of FSMA within the small business category proved to be company size. Chi-square analysis revealed significant results in preventive control practices and traceability infrastructure at divisions of 0-24 employees, and 25-499 employees. Companies that had 25-499 employees showed better preparation in implementing preventive controls for distinct FSMA compliance requirements. Also, companies that had 25-499 employees showed a leading advancement in technology adoption for establishment of traceability infrastructure versus companies that had 0-24 employees. The small business category spans a large range of employee sizes (499 or less). The results indicate that a special focus may be needed on businesses with less than 25 employees for FSMA preventive control requirements to be successful in small businesses.