In an article written by David Acheson, http://leavittpartnersblog.com/20113304/david-acheson/fda%E2%80%99s-views-on-preventive-control-requirements-beginning-to-emerge-time-to-go-beyond-haccp, he provides a view of FDA official comments, specifically that FSMA will go beyond HACCP. He suggests that FDA will put in more specific guidance to address key elements of food safety programs, pointing out that environmental monitoring and training will be two highlighted areas. Looking at the recalls we are seeing, it is hard to argue that prerequisite programs have become the primary issue with regard to outbreaks and recalls. Companies should begin looking at all programs that are responsible for controlling hazards to ensure they address monitoring, corrective actions, and verification.
While some will bristle at additional requirements, the cost of conducting a recall due to lack of control is worth the effort for improving low risk hazards are controlled.