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The Food Safety
  Modernization Act
How will it impact your company?

            March 5, 2013



                   1
Panelists
    Legal Perspective              IT Systems Perspective             Business Owner Perspective




    George Salmas                        Lynda Roth                       Larry Johnson
     The Food Lawyers®              LJR Consulting Services            Stanton Associates LLC
    20+ years experience           Business and IT Consultant;          Management Consultants
   advising and protecting      specializes in using technology to     with a focus on the food &
     food industry clients           increase profitability and       beverage industry; Founder/
                                 productivity in regulated industry   President of a specialty foods
                                such as food and pharmaceuticals                company


                             Moderator
                        Lewis Stanton
                     Stanton Associates LLC
                     Management Consultants
                     with a focus on the food &
                         beverage industry
                                                  2
Overview of Topics

     FSMA law - overview & structure
     Inspection of records
     Food facilities registration and suspension
     HACCP
     FDA inspection
     Tracking food shipments
     FDA recalls and administrative detention




                                   3
Goals of Our Program


     Giving the C-level exec an overview of the
      law to better lead the company


     Provide an understanding of how
      technology can help aid the process




                                  4
FSMA law is not yet complete
   Regulations not yet implemented
   Relationship of FSMA statute and Food
    & Drug Administration regulation
   Additional programs as regulations go
    into effect

                                                           Regulations, when
                                                             fully written and
                      LAW                                 implemented, will be
                                                            over 3,000 pages


                                                   Put out for
                            Regulations
                                                   public comment



                                 Final Published Regulations
                                          with effective date

                                  5
Structure of the FSMA


                Title I                      Title II
         Improving Capacity to       Improving Capacity to
          Prevent Food Safety        Detect and Respond to
               Problems              Food Safety Problems




                Title III                  Title IV
         Improving The Safety           Miscellaneous
           of Imported Food              Provisions




      = OUR FOCUS TODAY



                                 6
Inspection of Records and Protecting Trade Secrets

  When the FDA has the right to copy
   your records
  What can and cannot be copied
  Protecting trade secrets contained
   in copied documents
     FDA and the Freedom of
      Information Act




                                  7
Inspection of Records - IT implications


  Options for setting up your records
     Set up directories on different servers
     Get a good document management system
     Get a good ERP system




                                   8
Food Facilities Registration and Suspension


   Who must register
   FDA facilities registration
    number
   Suspension of registration
       Effect of suspension of
        registration
       Hearing on suspension within 2
        business days of suspension
       Reinstatement of registration




                                         9
HACCP Under FSMA


                      Hazard Analysis Critical
                       Control Point
                      What is it?
                      What you need to know
                      IT implications – monitoring
                       the control points




                   10
FDA Inspection of Domestic Food Facilities

   “High Risk” and “Low Risk”
    food facilities
      How a strong ‘Quality
       Compliance’ system can aid
       in being a low risk food facility
   Frequency of inspections
   FDA inspection fees
   Technology and the FDA
    inspection process
      Systems that demonstrate a
       high level of organization




                                           11
Tracing and Tracking Food Shipments


                       Records that must be kept
                       “One step up and one step down”
                        the food chain
                       Tracking batches, lots and cases
                       The role of CRM, ERP and
                        Quality Compliance systems in
                        record keeping
                          How the right ERP system can make
                           tracking automatic




                        12
FDA Recall Authority and Procedures


   Recalls before FSMA
   Recalls under FSMA
   Making recalls easy using
    ERP and Quality Assurance




                                13
Administrative Detention of Food


                            Basis for detention
                            Appeals to FDA
                            Federal Court Actions




                         14
The bottom line on how the
Food Safety Modernization Act
affects you



                            Business Owner Perspective
            Larry Johnson
   Stanton Associates LLC



                            IT Systems Perspective
              Lynda Roth
  LJR Consulting Services



                            Legal Perspective
         George Salmas
      The Food Lawyers®




                                   15
Offer to webinar participants*:

    Each Alliance member would be
    pleased to offer a complimentary
         one-hour consultation.

* Webinar participants within the food & beverage industry
                               16
Contact Information


Lewis Stanton                          George Salmas
Stanton Associates LLC                 The Food Lawyers®
lstanton@stantonassoc.com              George.Salmas@thefoodlawyers.com
818-752-6500                           310 556-0721


Larry Johnson                          Lynda Roth
Stanton Associates LLC                 LJR Consulting Services
ljohnson@stantonassociates.com         lynda.roth@ljrconsultingservices.com
818-752-6500                           818-709-658




                                  17
Q&A




      18
Thank you
for joining us!

       19

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Food Safety Modernization Act Webinar

  • 1. The Food Safety Modernization Act How will it impact your company? March 5, 2013 1
  • 2. Panelists Legal Perspective IT Systems Perspective Business Owner Perspective George Salmas Lynda Roth Larry Johnson The Food Lawyers® LJR Consulting Services Stanton Associates LLC 20+ years experience Business and IT Consultant; Management Consultants advising and protecting specializes in using technology to with a focus on the food & food industry clients increase profitability and beverage industry; Founder/ productivity in regulated industry President of a specialty foods such as food and pharmaceuticals company Moderator Lewis Stanton Stanton Associates LLC Management Consultants with a focus on the food & beverage industry 2
  • 3. Overview of Topics   FSMA law - overview & structure   Inspection of records   Food facilities registration and suspension   HACCP   FDA inspection   Tracking food shipments   FDA recalls and administrative detention 3
  • 4. Goals of Our Program   Giving the C-level exec an overview of the law to better lead the company   Provide an understanding of how technology can help aid the process 4
  • 5. FSMA law is not yet complete   Regulations not yet implemented   Relationship of FSMA statute and Food & Drug Administration regulation   Additional programs as regulations go into effect Regulations, when fully written and LAW implemented, will be over 3,000 pages Put out for Regulations public comment Final Published Regulations with effective date 5
  • 6. Structure of the FSMA Title I Title II Improving Capacity to Improving Capacity to Prevent Food Safety Detect and Respond to Problems Food Safety Problems Title III Title IV Improving The Safety Miscellaneous of Imported Food Provisions = OUR FOCUS TODAY 6
  • 7. Inspection of Records and Protecting Trade Secrets   When the FDA has the right to copy your records   What can and cannot be copied   Protecting trade secrets contained in copied documents   FDA and the Freedom of Information Act 7
  • 8. Inspection of Records - IT implications   Options for setting up your records   Set up directories on different servers   Get a good document management system   Get a good ERP system 8
  • 9. Food Facilities Registration and Suspension   Who must register   FDA facilities registration number   Suspension of registration   Effect of suspension of registration   Hearing on suspension within 2 business days of suspension   Reinstatement of registration 9
  • 10. HACCP Under FSMA   Hazard Analysis Critical Control Point   What is it?   What you need to know   IT implications – monitoring the control points 10
  • 11. FDA Inspection of Domestic Food Facilities   “High Risk” and “Low Risk” food facilities   How a strong ‘Quality Compliance’ system can aid in being a low risk food facility   Frequency of inspections   FDA inspection fees   Technology and the FDA inspection process   Systems that demonstrate a high level of organization 11
  • 12. Tracing and Tracking Food Shipments   Records that must be kept   “One step up and one step down” the food chain   Tracking batches, lots and cases   The role of CRM, ERP and Quality Compliance systems in record keeping   How the right ERP system can make tracking automatic 12
  • 13. FDA Recall Authority and Procedures   Recalls before FSMA   Recalls under FSMA   Making recalls easy using ERP and Quality Assurance 13
  • 14. Administrative Detention of Food   Basis for detention   Appeals to FDA   Federal Court Actions 14
  • 15. The bottom line on how the Food Safety Modernization Act affects you Business Owner Perspective Larry Johnson Stanton Associates LLC IT Systems Perspective Lynda Roth LJR Consulting Services Legal Perspective George Salmas The Food Lawyers® 15
  • 16. Offer to webinar participants*: Each Alliance member would be pleased to offer a complimentary one-hour consultation. * Webinar participants within the food & beverage industry 16
  • 17. Contact Information Lewis Stanton George Salmas Stanton Associates LLC The Food Lawyers® lstanton@stantonassoc.com George.Salmas@thefoodlawyers.com 818-752-6500 310 556-0721 Larry Johnson Lynda Roth Stanton Associates LLC LJR Consulting Services ljohnson@stantonassociates.com lynda.roth@ljrconsultingservices.com 818-752-6500 818-709-658 17
  • 18. Q&A 18