FSMA Preventive Controls

Aligned with FSSC 22000 – Optional Compliance Enhancement for U.S. FDA FSMA

Requirement Overview

The FSMA Preventive Controls Add-On is an optional enhancement for food facilities certified under FSSC 22000. It aligns your Food Safety Management System (FSMS) with the U.S. FDA’s Food Safety Modernization Act (FSMA), specifically 21 CFR Part 117: Current Good Manufacturing Practice, Hazard Analysis, and Risk-Based Preventive Controls for Human Food.

This module complements your ISO 22000-based FSMS by incorporating FSMA-specific requirements such as hazard analysis, preventive controls, recall planning, supply-chain controls, and recordkeeping—critical for facilities exporting to the U.S. or undergoing FDA inspections.

Aligned with BRCGS for Storage & Distribution Issue 4 – Clause 4.3.1 & 4.3.3

Requirement Overview

BRCGS for Storage & Distribution requires that products moved via cross-docking are traceable and controlled at all times, even when they are not held in storage for extended periods.

Clause 4.3.1: “The company shall ensure that traceability is maintained at all stages, including during cross-docking operations.”
Clause 4.3.3: “Procedures shall be in place to ensure that all products handled, including those not stored on-site, remain under control and are not subject to contamination or substitution.”

Cross-docking operations must not compromise product traceability, safety, or integrity. Even with minimal handling and temporary presence, each product must be accurately identified, documented, and protected.

Key Compliance Objectives

  • Map FSMA-specific controls into your FSSC 22000 FSMS

    Demonstrate 21 CFR 117 alignment during FDA inspections

    Implement Hazard Analysis and Risk-Based Preventive Controls (HARPC)

    Define qualified roles and maintain compliant records

Step-by-Step Compliance Implementation

1. Conduct a HARPC-Based Hazard Analysis

  • Activities:

    • Identify known or reasonably foreseeable hazards (biological, chemical, physical, radiological, economically motivated adulteration)

      Evaluate severity and likelihood

    Evidence to Maintain:

    • FSMA-aligned hazard analysis documentation

      Justifications for exclusion/inclusion of hazards

      Qualified Individual (QI/PCQI) signature

2. Identify and Implement Preventive Controls

  • Controls May Include:

    • Process controls (e.g., temperature, pH)

      Sanitation and allergen controls

      Supply-chain controls

      Recall plans meeting FSMA standards

    Records to Maintain:

    • Monitoring and verification records

      Corrective actions

      Documented recall procedures in compliance with 21 CFR 117.139

3. Designate a Preventive Controls Qualified Individual (PCQI)

  • PCQI Responsibilities:

    • Oversee FSMA elements of the FSMS

      Validate and reanalyze controls

    Evidence to Maintain:

    • PCQI training certificate or documentation

      Food safety plan signed by PCQI

      Review logs and change records

4. Establish a FSMA-Compliant Supply-Chain Program

  • If receiving ingredients requiring control:

    • Verify suppliers via audits, COAs, sampling, or approved documentation

      Keep supplier verification and approval records

    Evidence to Maintain:

    • Supplier risk assessments

      Audit results and control documentation

      Justifications for exemptions

5. Maintain FSMA Recordkeeping and Reanalysis

  • Plan Components:

    • Keep records for a minimum of 2 years

      Ensure quick access during FDA inspection

      Conduct reanalysis at least every 3 years or upon significant changes

    Evidence to Maintain:

    • Controlled records aligned with 21 CFR 117 Subparts C & G

      Reanalysis logs

      Traceability of decisions and updates

Common Audit Findings & Recommended Fixes

Audit Finding Recommended Action
No HARPC-based hazard analysis Update your hazard analysis to align with FSMA
PCQI role not assigned or documented Assign and train a PCQI, keep documentation
Recall plan missing FSMA elements Revise to include FDA-mandated responsibilities
No supply-chain program for controlled hazards Implement supplier verification and maintain proof

Auditor Verification Checklist

Prepare for audits or inspections by having:

  • FSMA-aligned hazard analysis

    Preventive control and recall documentation

    PCQI designation and credentials

    Supplier approval and verification logs

    Record retention plan and procedures

Implementation Roadmap

Build Your Program

  • Perform FSMA/HARPC-based hazard analysis

    Assign and train your PCQI

Train and Apply

  • Implement preventive controls and supplier programs

    Document procedures and monitor compliance

Monitor and Review

  • Conduct FSMA-focused internal audits

    Reanalyze your food safety plan regularly

Strengthen Continuously

  • Use audit findings for system improvements

    Keep PCQI training and food safety plans current

Why This Matters?

  • Dual compliance with FSSC 22000 + U.S. FDA FSMA

    Strengthens export readiness for the U.S. market

    Helps avoid FDA Form 483 observations

    Enhances credibility with regulatory bodies and buyers

Support Tools Available

Food Safety Systems provides:

  • FSMA-aligned hazard analysis templates

    PCQI training resources

    Supply-chain verification forms

    Recall plan templates aligned with FDA requirements