Crosswalk Between the Standards
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1 Crosswalk Between the Standards Julie Loera Food Safety Officer Texas Department of State Health Services Kim Stryker Program Manager Alaska Food Safety and Sanitation
2 Standards Crosswalk Workgroup Committee Purpose 1. Analyze VNRFRPS (Retail), AFRPS (Animal Feed), and MFRPS (Food) 2. Identify potential areas of alignment or harmonization specifically from the MFRPS perspective for the next round of MFRPS revisions.
3 Standards Crosswalk Workgroup Committee Charge This process may 1. identify areas from the other standards that contain elements that should be added to the MFRPS (Standard 11 from the AFRPS, for example); or 2. suggest elements that should be deleted or modified (the format of some of the appendices, for example). This will result in a final recommendations document that will be available to the standards revisions workgroup beginning sometime in 2018
4 Standards Crosswalk Workgroup Committee Membership 1. MFRPA Board members, 2. State representatives, and 3. FDA SIS and AS staff members or more as identified
5 Committee Members Michael Antee U. S. Food and Drug Administration Amber Grisamore State of Kansas Patrick Guzzle State of Idaho Maria Ishida State of New York Ali Kashani State of Washington Jan Kelly State of Minnesota Stacy King State of West Virginia Tressa Madden* U.S. Food and Drug Administration Steve Morris State of Kansas Steve Mandernach State of Iowa Julie Loera* State of Texas Priscilla Neves U.S. Food and Drug Administration Carolina Schaffer State of Florida Kim Stryker* State of Alaska * MFRPA Board Member
6 Harmonization Opportunities Limited Opportunities Found different purpose for standard different techniques utilized different laws and rules Other Possibilities? Report findings Share with other standards programs
7 Harmonization Opportunities Standard 1 Terms: Equivalent/Equivalent in Effect/Not Equivalent vs Full Intent/Partial Intent/No Corresponding 95% Equivalent
8 Harmonization Opportunities Use similar forms Use similar language Standard 6 possible broadening of terms not specific yes/no vs acceptable/not acceptable
9 Harmonization Opportunities Standard 8 MFRPS VNRFRPS AFRPS Evaluation Frequency 12 months 36 months 36 months AFRPS requires an evaluation of every three years. MFRPS must assess yearly. Possible reduction? Forms very different between all 3 standards. Option to harmonize the forms?
10 Harmonization Opportunities Standard 9 MFRPS VNRFRPS AFRPS Self Assessment Frequency 12 months 60 months 36 months Self Assessment Form > elements Third Party Audit Yes (FDA) Yes No, unless funded Improvement Plan Yes Yes Yes Could assessment be reduced to 36 months to match up with AFRPS Could self assessment forms be changed - MFRPS form has more elements than AFRPS to include hours spent on each standard (for OMB). AFRPS third party audit - but not mandate it be FDA. Funding requirements could mandate FDA if needed. Improvement Plan - Elements are similar enough between MFRPS & AFRPS - one format for reporting between the programs.
11 Differences Formats * Terminology * Timeframes * Documentation * Forms Standard 2 Excerpt
12 effective inspection program utilization of HACCP principles determine compliance with laws focuses on the status of risk factors, determines and documents compliance, and targets immediate- and long-term correction through active managerial control. Standard 3 Excerpt
13 must use risk factors & classification criteria described develops & uses a process that groups into at least three categories based on potential & inherent food safety risks required to use a minimum of three factors in to assign risk categories Standard 3 Excerpt
14 There s Got to Be a Better Way Public Health Accreditation International Standard ISO (Inspection Bodies) International Comparability Assessment Tool
15 BACKGROUND objective framework to determine robustness of potential participating country s food safety authority s overall food safety systems. originally based on MFRPS in 2008, a voluntary program that aligns domestic U.S. FDA to U.S. states food safety systems. modifications made to provide tool more suitable for international use.
16 STANDARD 1 Narrative Legal and Regulatory Foundation Purpose of the Standard - The Regulatory Foundation Standard describes the laws, regulations, rules, ordinances, or other regulatory requirements that govern the operation of a food safety control system which are used by participating country to define and ensure compliance with food safety regulations.
17 STANDARD 1 Narrative Legal and Regulatory Foundation Basic Requirement of this Standard To demonstrate that the participating country has the legal authority and regulatory provisions to perform inspections and investigations, gather evidence, collect and analyze samples, and take enforcement actions to protect the public health by ensuring the safety and security of the food supply.
18 STANDARD 1 Narrative Legal and Regulatory Foundation Program Elements to Satisfy Basic Requirements: 1. Legal Authority - Describes the set of laws which provide the participating country with the legal authority to protect the public health by ensuring the safety and security of the food supply, by performing such actions as: inspections and investigations, gathering evidence, collecting samples, and enforcement. 2. Regulatory Foundation Describe the set of regulations that provide the provisions. 3. Documentation Food safety laws and regulations are documented, maintained, and accessible
19 STANDARD 1 Worksheet Legal and Regulatory Foundation
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23 What Now? Report Harmonization Opportunities to MFRPA Board Share findings with other Standards Programs Collaboration among Standards Groups Feedback to Alliance Representatives Input and Participation on Workgroups Continue to Explore Concept of Generalized Standards
24 Contact Information Julie Loera Food Safety Officer Texas Department of State Health Services Kim Stryker Program Manager Alaska Food Safety and Sanitation
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