In Part Three of FSMA Fridays: Food Safety Plans — HACCP To HARPC, SafetyChain’s Jill Bender was joined by The Acheson Group’s Dr. David Acheson and Dr. Peyman Fatemi to detail what the FDA expects regarding compliance to a HARPC-based food safety plan and when the agency will begin expecting it. Here, in the fourth, and final, segment of the series, the trio will begin handling questions from webinar’s live audience.
Jill: As always, there are some questions that have come in from out attendees. Here is a question about smaller companies and the time line for companies under that 500 mark. Is there any guidance related to that, David?
David: We have another 12 months for that. If you’re less than 500 employees, full-time equivalents, you have until September 2017 to be compliant. If you’re more than 500 — this is preventative control rules, let’s be clear. If you are more than 500, you have to be compliant by September of this year, just down the road.
One point of clarification there, because people get confused, is that like 500 per facility or what is it? Our read of this is 500 in the whole organization, the whole enterprise. For example, if you are a manufacturing facility with three plants and you have 200 people in each one of them, then collectively as an organization you’ve got 600 individuals, equivalents. This makes you more than 500 across the whole organization and enterprise. That kicks you into being a non-small business. Keep that in mind, it’s not just per facility, it’s across the entire enterprise.