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OFW Law has prepared comprehensive memoranda on two major FDA proposed rules, which FDA has characterized as the cornerstones of the new food safety system created by the Food Safety Modernization Act:

  • Proposed Rule under FSMA for Preventive Controls for Human Food: Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventive Controls for Human Food
  • Proposed Rule under FSMA for Produce: Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption

In short, the first proposed rule wold require most food facilities to implement HAACP-like food safety plans.  The second would require most farms and “farm mixed-type facilities” that grow, harvest, pack, or hold produce to comply with the new safety standards.  Both proposed rules were published on January 16, 2013, and comments on both are due May 16, 2013.

The proposed rule on Preventive Controls for Human Food will be discussed in detail at the webinar OFW Law is presenting in conjunction with The Food Institute next Thursday, January 24.  Refer to the previous post for more information on the webinar.

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