Managing risk isn’t easy, especially in an industry that’s becoming increasingly global. Bakers realize now that their ascorbic acid probably was brewed in China. Or perhaps the hard-fat base stock of their shortening grew in Malaysia.

Traceability, documentation and a relentless onslaught of audits have become the realities of business today, and it’s likely to get much more complicated in the near future. According to Jim McCarthy, president and CEO of the Snack Food Association, the Food and Drug Administration (FDA) sent a letter to the association saying it plans to release regulations carrying out the Food Safety Modernization Act (FSMA) shortly after the dust settles following the November election.

That’s not surprising, even though deadlines for several of the initial regulations have long passed, according to discussions I’ve had with Laurie Gorton, our executive editor who attended the recent AACC International annual meeting in Hollywood, FL, where FSMA (pronounced fiz-mah) was one of the “hot topic” sessions. That’s because the regulations will likely require a ton of retraining and create a burden, especially on small to mid-sized companies.

“It’s going to cost a bag o’ bucks because you’ll need a full-time regulatory person if you don’t have one now,” she said. “Many small companies already ask their quality assurance person to double up on duties. I talked to a couple of such individuals at the AACCI meeting, and they are absolutely swamped by requests for traceability, sustainability and other reports from their major retail and food service customers.”

Ideally, FSMA will reduce the number of audits that have proliferated since the massive peanut butter recall a few years back. We’ll see if that happens. Keep in mind FSMA’s emphasis is on preventive controls, not just monitoring critical control points. In many ways, FSMA might end up being HACCP on steroids for many operations.

According to Ms. Gorton, bakers and snack producers don’t have to wait until the hammer falls to develop an action plan to deal with this issue. She recommended that companies sign up for FDA email notifications. The agency’s website provides a link to this service though its pages about food safety. AIB International also offers a bevy of information in its library’s Knowledge Center. Also:

•  Sign up for Sosland’s Food Safety Monitor e-newsletter, which will cover this issue as it unfolds.

•  Update your HACCP documents and training programs to lay the foundation for dealing with future regulations.

•  Work with your third-party auditors to minimize any surprises that may occur when the regulations come out.

•  Finally, get active with our industry associations and their various committees. As Ms. Gorton noted, “To have a seat at the table, you need to get involved.”

In the end, an ounce of preparation may prevent a pound of problems.