“We did what you asked, now you actually want us to write it down too?”
Yes. And, keep it in a file. And, have it available when the FDA inspector comes a calling.
“What does the documentation aspect of the FSMA have to do with pallets anyway? Haven’t we got enough to worry about keeping track of our hand washing?”
Well, let me explain more about the FSMA…
Establishing a food safety system
The Food Safety Modernization Act has been crafted to help prevent conditions that might make people sick. This means those facilities covered by the Act must establish and implement a food safety system that includes an analysis of hazards and risk-based preventive controls. The rule sets requirements for a written food safety plan that includes:
Pallets cannot be ignored
The purpose of FSMA documentation procedures is to make sure:
FSMA records and written plans
“So what is it you want me to write down?”
When it comes to pallets, just about everything. Think of it as a cradle-to-grave operation.
When an incident happens, one of the first questions to be asked is, “where did the pallets come from?” Your complete records should be ready with:
You should also include a written plan for day-to-day pallet management including:
Writing the plan is only half of the equation. Records verifying your day-to-day implementation of the plan will need to be available to the FDA upon an inspection. The key word here is verification. And I can assure you my friend, if you did not write it down, it did not happen.
Still have questions about FSMA documentation requirements and how they relate to pallets? Feel free to comment here or drop me a line.
Post by: Hartson Poland, Business Development - Plastic
Use of FDA Inspector photo is made available by the U.S. Food and Drug Administration.
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