The Food Safety Modernization Act has now been a reality for a few months. We want to urge you to familiarize your organizations with it and to understand how best to prepare for its requirements – including revisiting your recall programs and recall insurance policies, revisiting or adopting an inspection policy, and revamping your record-keeping program. Please be advised that many of the Act’s requirements were not effective immediately, but are to be implemented over the course of the next few years (and some of those provisions have begun to become effective). We urge you to keep updated on upcoming implementation dates so that nothing “falls through the cracks” and adversely surprises your business.
(Editor's Note: Attorney Steve Kluting authored this post while working in Varnum's Grand Rapids office. Steve is currently with another company.)