FSMA Update


As FSNS C&A is auditing plants under FDA jurisdiction, we are evaluating each facility’s Food Safety plan for compliance under FSMA requirements 21 CFR 117 (Human Food) and 21 CFR 507 (Animal Food). Adoption of these elements of the Code of Federal Regulations is a regulatory requirement each facility producing FDA products and the plant must be in compliance with the regulations.

One of the requirements within the regulation poses a new twist on a previous element that we have audited when performing Food Safety audits and GFSI Certification audits. 21 CRF 117.37 (b) (5) and 21 CRF 507.20 (b) (5) state the following with regard to plumbing at each facility. “Ensure that there is no backflow from, or cross-connection between, piping systems that discharge waste water or sewage and piping systems that carry water for food or food manufacturing (animal food or animal food manufacturing.)”

In the past, as an auditing company, we were focused on verification that a backflow device was in place on the main water line coming into the facility. The new requirement address cross-contamination between potable water systems and drains. As we have all seen, it is not uncommon to observe wash-down or other hoses left on the floor or near drains. If not properly protected, “back-syphonage” occurs and the water from the drains could potentially contaminate the potable water system. Our interpretation is that there should be some type of back-syphonage device on water lines/ hoses that could come into contact with drains or areas where water or fluids could pose a risk of contamination to the potable water system.

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