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FSMA

2020 FSMA Dates for Small Food Businesses


As the year comes to a close, it is important to ensure your food safety “house” is in order. Many Food Safety and Modernization Act (FSMA) deadlines have already passed, meaning that most food brands are required to be FSMA compliant today. For smaller businesses, specifically, there are a few key dates still on the horizon.

If you are unsure about whether your brand is currently compliant, review FSMA compliance dates to make sure your business practices are operating in accordance with FDA regulations. For larger and medium-sized businesses, rules are largely already in effect for preventive controls, produce safety, foreign supplier verification, sanitary transportation, and intentional adulteration. Keeping this in mind, we anticipate that regulatory standards will continue to evolve, so falling behind now can have compounding effects down the line.  Review the key FSMA deadlines slated for 2020 below:


2020 Produce Safety Rule Dates

Routine Inspections on Small Farms: The FDA has announced that they are allowing states flexibility around when they begin routine inspections on small farms (other than sprouts operations). Under the Produce Safety Rule, states are generally slated to start routine inspections of small farms in the spring of 2020. However, some states may begin inspections as early as January 1st, 2020. Read more about inspections here.

Compliance for Small, Covered Farms: Small produce farms engaging in covered activities will need to be compliant with the Produce Safety Rule in 2020. Businesses that have an average monetary value of more than $25,000 but no more than $250,000 over the previous 3 years will need to be compliant starting January 27th, 2020. Larger businesses should already be compliant with the rule.


2020 Preventive Controls Dates

Preventive Controls for Human Food: Very small businesses, defined within this rule as averaging less than $1 million per year over the last three years, needed to be compliant with this rule as of September 17th, 2018. However, the FDA has announced an extended compliance date of January 27th, 2020 for very small businesses that have:

  • Facilities solely engaged in packing and/or holding activities on produce raw agricultural commodities (RACs)
  • Facilities that would qualify as secondary activities farms, except for ownership
  • Facilities that would qualify as farms if they did not color RACs

Preventive Controls for Animal Food: Very small businesses, defined within this rule as averaging less than $2.5 million per year over the last three years, originally needed to be compliant with this rule as of September 17th, 2018. However, there is an extended compliance date of January 27th, 2020 for very small businesses that have:

  • Facilities solely engaged in packing and/or holding activities on produce RACs and/or nut hulls and shells
  • Facilities that would qualify as secondary activities farms, except for ownership

2020 Intentional Adulteration Dates

Small businesses, i.e. businesses employing less than 500 full-time equivalent employees, must be compliant with the Intentional Adulteration (IA) rule by July 27th, 2020.


2020 Foreign Supplier Verification Program (FSVP) Dates

Food brands need to ensure their foreign suppliers are also compliant with US food and safety regulations. Most FSVP deadlines are scheduled to go into effect after other FSMA deadlines, in order to allow importers’ prioritization of their own compliance before verifying their foreign suppliers’. If you have foreign suppliers that fall under the 2020 deadlines for produce safety rules or preventive control rules, be sure to consult the corresponding FSVP deadlines. And if you have foreign suppliers, make sure you have all the records required under FSVP.


How To Prepare for Future Regulation

The FDA has consistently rolled out FSMA deadlines since the law was ratified in 2011. These rules have laid the foundation for a more transparent food industry, while preparing companies for future regulatory initiatives. The FDA’s recent campaign on a New Era of Smarter Food Safety indicates that there are more advanced food safety requirements on the horizon, and that the regulatory body could be drafting more rules to advance traceability, sustainability, and preventive food quality processes. 

Food brands can prepare their businesses by building robust food safety and supplier management programs. Learn how you can stay compliant while building true traceability into your supply chain by speaking with a FoodLogiQ expert.

Posted by Anna Ploegh on Dec 10, 2019 6:21:57 PM

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