The Dirt on “Clean” Labels

Everybody wants “clean” labels. But, what does that mean? With no legal definition, “clean” labeling encompasses a wide-range of claims, such as natural, healthy, -free, simple, small-batch, no preservatives, no artificial colors or flavors, made from nature, made from kitchen ingredients, and pasture-raised. Underlying the “clean” … Continue Reading

Pondering Public Disclosure & FSMA Records

Remember last month when we said to DOCUMENT EVERYTHING under the Food Safety Modernization Act (FSMA)? Well, here’s some more context for that recommendation.

For one, FSMA adds a substantial amount of documentation and record-keeping requirements for food companies that are covered by any one or more of FSMA’s new regulations. For example:

  • Food facilities—those
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FDA to Redefine “Healthy”

The term “healthy” as commonly used is quite subjective—meaning different things to different types of consumers. Culturally, there are sometimes fast-changing trends about what is healthy—foods rejected by consumers a few years ago are now regaining popularity and vice versa. Nevertheless, the FDA defines “healthy” and regulates how Continue Reading

Responsibility for FSMA Preventive Controls: If Not You, Then Who?

We wrote earlier this week about the Food Safety Modernization Act (FSMA) and what it means, from a 30,000 foot perspective, for food companies. Today we are going to dig in a little deeper to one issue that we’ve seen clients wrestle with recently.

One core FSMA requirement is a new process that requires identification and prevention of all reasonably foreseeable… Continue Reading

Manic Monday: FSMA Compliance Starts Today!

Today, Sept. 19, 2016, is a big day for the food industry. It is the first compliance deadline[1] for regulations under the Food Safety Modernization Act (FSMA) – the law we’ve been talking about since 2011, the law touted as the most sweeping reform of food safety laws in more than 70 years.

So, what’s all the big fuss about?

Yes, “food facilities” (companies… Continue Reading

Summer vacay? Not for FDA.

While you were (hopefully) lounging at the beach or hiking mountains, the FDA was hard at work in Washington D.C. churning out final rules and guidance documents that impact food companies in various, and sometimes substantial, ways.

Some of those updates were expected (e.g., Nutrition Facts updates) and some were a surprise (e.g., a finalized GRAS rule, … Continue Reading

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