Thompson Coburn presents a CLE on FSMA, looming deadlines and new regulations: Is the food industry ready?

The US Food and Drug Administration continues its ongoing implementation of the Food Safety Modernization Act of 2011 (FSMA). The law, which aimed to take the first hard look at the American food supply in decades, has resulted in a multipronged assessment and update to how companies selling, manufacturing, processing, storing, packing, shipping or otherwise handling food products in the US must operate in order to remain in compliance with FDA regulations. Particularly, over the course of the last two years, the FDA has been on a record pace, passing new regulations that have completely rewritten the rulebook on food safety regulation in the United States.

Throughout this period, the Life Sciences Decoded team at Thompson Coburn, headed by Diane Romza-Kutz, has been continually monitoring the creation of the new regulations that have implemented FSMA’s changes. While there are many new regulations, Life Sciences Decoded has covered those that have made some of the most far-ranging changes that impact the most companies.

They have included:

• The new Nutrition Facts Panel that appears on the vast majority of food products in the US, including changes regarding the disclosure of sugars
• The banning of Trans Fats by the FDA
• The creation of Hazard Analysis and Risk-based Preventive Control, or HARPC, plans and the update of the FDA Current Good Manufacturing Practices, or cGMPs. (See parts I, II, and III.)
• The Foreign Supplier Verification Program for importers of food for humans and animals
• The new Produce Safety Rule, covering general farming operations and the growing of several specific produce products
• The Sanitary Transport of food for humans and animals.

Combined, these are sweeping new rules, with many idiosyncrasies that will impact different segments of the food and chemical industries, and different steps in the manufacturing shipping, packaging and distribution process, in varying ways. And as important as the content of the rules themselves are the deadlines for compliance that have either already arrived, or will be over the next few months and years. It is vital for all members of the food industry to understand these rules and create compliance programs in order to comply with the new law.

On Tuesday, October 4, 2016, at 2:30 p.m. CDT, Thompson Coburn Partners Diane Romza-Kutz andKimberly Bousquet will discuss FSMA, some of its requirements, and the looming deadlines for compliance. After their presentation, Thompson Coburn will be hosting a networking period with food and drinks, to discuss the particular concerns of these new rules and compliance with them poses for the food and related industries.