By Jill Hollingsworth, VP, Food Safety and Retail Industry Relations, Ecolab
Maybe you have heard the acronyms FSMS and AMC, but do you know what they stand for and why they are important to retailers? According to the FDA, they may be the most important things you can do to ensure regulatory compliance. Here is what you should know…
Food Safety Management Systems and Active Managerial Controls
A Food Safety Management System (FSMS) refers to a specific set of actions and/or procedures to help achieve managerial control. FSMS includes the development and implementation of 3 major food safety components of your operations: procedures, training, and monitoring.
According to the FDA Food Code, Active Managerial Control (AMC) means the “purposeful incorporation of specific actions or procedures by industry management into the operation of their business to attain control over foodborne illness risk factors.” The FDA further describes “active managerial control” as industry’s responsibility for developing and implementing systems to reduce the occurrence of foodborne illness risk factors.
Although you may not routinely use these terms, the basic management principles being used in the day-to-day operations of your stores are AMCs, which make up your FSMS. There are many tools that can be used by retailers to ensure they have active managerial control over risk factors. AMC actions are based on identification of food safety risks and a proactive preventive approach through a continuous system of assessing, implementing, and monitoring.
Elements of an effective FSMS may include the following:
- Written procedures for those actions such as cleaning/sanitizing and handwashing which are known to control specific foodborne illness risk factors
- Standard operating procedures (SOPs) or detailed instructions for performing critical operational steps that impact food safety such as cooking or temperature checks
- Food safety critical limits such as cold holding temperatures
- Monitoring procedures, defined corrective actions, and record keeping when required
- Employee health policy for restricting or excluding ill employees
- Manager and employee training
- Certified Food Protection Managers on site who are also the Person-In-Charge
- Independent audits or assessments
Assessing Food Safety Management Systems
In May 2021, FDA released the FDA Report on the Occurrence of Foodborne Illness Risk Factors in Retail Food Store Deli Departments*. FDA found that the implementation of a FSMS was the strongest predictor of compliance status to the control of risk factors. As an establishment improved the development of its FSMS, the average number of primary data items out-of-compliance was reduced, resulting in reduced occurrence of foodborne illness risk factors.
In this same study, FDA used three key elements to assess a deli department’s FSMS:
- Procedures (P): A defined set of actions adopted by management for accomplishing a task in a way that minimizes food safety risks
- Training (T): The process of management’s informing employees of the food safety procedures within the deli and teaching employees how to carry them out
- Monitoring (M): Routine observations and measurements conducted to determine if food safety procedures are being followed and maintained
For each of these three elements, the person in charge was interviewed to assess the level of FSMS based on these criteria:
- Management is able to describe the critical limits for a specific procedure
- Management is able to describe the steps/tasks (how and when) that are performed to ensure the identified critical limits are achieved
- Management is able to identify specific employees that have been assigned the responsibility to correctly perform the specific procedure
- Management is able to produce written materials (standard operating procedures, posters, wall charts, wallet cards, ) that support implementing the system to control the specific risk factor
FSMS were ranked as follows:
- Nonexistent: No system in place or system haphazardly implemented (no defined structure or frequency for implementation).
- Underdeveloped: System is in early development. Efforts are being made, but there are crucial gaps in completeness and/or consistency.
- Well-developed: System is complete, consistent, and oral or a combination of oral and
written. The preponderance of the management system is oral.
- Well-developed and Documented: System is complete, consistent, and primarily written. The preponderance of the management system is written.
Responsibility for food safety at the retail level lies with retail managers and employees, and their ability to effectively maintain control over foodborne illness risk factors. Understanding the importance of Active Managerial Controls and implementing a Food Safety Management System will not only help to ensure regulatory compliance, but also protect your customers and your company’s reputation.
*For the full report, go to: https://www.fda.gov/media/148247/download