In 2017, at the annual IAFP (International Association for Food Protection) meeting, I chaired a mini-symposium on this topic, focused on looking at the evolution of FSMA and how it complies or conflicts with the GFSI standards. I had an expert panel of three professionals; a Corporate QA Director (of RTE products), a Supply Chain expert from NSF, and the Technical Director of SQFI. The overwhelming consensus was that GFSI and FSMA were highly complementary.
In fact, while Preventive Controls (FDA Terminology) are not found in either SQF or the other GFSI schemes, all schemes deal with the development, verification, and improvement of all pre-requisite programs. Furthermore, the new versions of SQF and BRC – the two primary GFSI schemes we deal with in North America – both address and create complementary programs that enhance the synergies between a GFSI scheme and FSMA.
In reference to FSMA and the brewing industry, “alcoholic beverage manufacturers are required to comply with multiple portions of 21 CFR 117 (FSMA) in order to ensure a safe and unadulterated product” [1].
The Brewers Association’s (BA), Chuck Skypeck, maintains that the preventive controls approach of FSMA complements both the increasing regulatory mandates and customer demands. BA wants to create the tools that drives crafters to comply with FSMA. One of these expectations is to develop an industry-recognized certified food safety plan like a GFSI scheme! Last, the program should be expandable and usable from Brewpubs and tap room breweries to large craft breweries exceeding 50,000 bbls/annum.
In fact, on the BA website dated Feb 19, 2019, BA announced a contract with a committee to provide guidance for Food Safety Preventive Controls [2]. So, there seems to a be an organic, evolving development of both GFSI and Preventive Controls in the craft brewing markets.
How do we integrate HACCP, GFSI and FSMA while creating cutting edge brews?
In conclusion, a brewery can either opt to formally get certified in a GFSI scheme, both for the food safety and quality benefits, or simply incorporate the scheme to enhance its operation’s efficiencies and growth. Breweries that implement the scheme have the potential to streamline procurement, improve production, and enhance their quality programs. None of these schemes seek to erase a unique brewing culture. Their intent is to provide the brewery with programs and a backbone for not only the QA department, but for the entire operation.
I maintain a brewery’s ethos and culture can be enhanced and protected by SQF food safety and quality programs in concert with FSMA Preventive Controls. As the craft brewery market continues to evolve, incorporating GFSI schemes and Preventive Controls will ensure the industry’s vitality and growth.
Sources:
[1] Skypeck, Chuck, Tech. Brewing Projects Mngr. Food Safety Preventive Controls for Breweries, Brewers Association
https://s3-us-west-2amazonaws.com/brewersassoc/wp-content/uploads/2019/02/Food-Safety
{2} https://www.brewersassociation.org/industry-updates/preventive-controls/