FSMA Compliance is Now Law

With passage of the “Food Safety Modernization Act” (FSMA), the FDA is now labeling ice and condensation as a source of contamination in the food industry. Read our technical paper explaining how Vapor Armour can help you get ahead of the FSMA curve.

12/19/16: What Can You Do if You Have Not Yet Taken Action on FSMA?

In September of this year, the compliance deadlines for the Food Safety Modernization Act (FSMA) arrived. If you’re an executive, you’re probably already well aware of the requirements – and the penalties – for the members of the cold-storage industry. But what do you do if you’re behind on implementing your compliance plan? This article from Food Safety Magazine offers three basic action items that will help you get the ball rolling.

To read more, click here.

11/30/16: A New Era of Food Safety Regulation Begins

This fall, after five years of preparation, the first major compliance deadlines associated with the Food Safety Modernization Act (FSMA) arrived, and with them the enforcement stage. So what can cold-storage facilities expect? In this article from Food Safety Magazine, three attorneys break down each of the new rules with an eye towards their practical challenges and ways in which enforcement might provide clarity. It’s a must-read for any facility manager concerned with how they’ll deal with these challenging new regulations.

To read more, click here.

10/22/16: The First FSMA Compliance Dates Are Here – What Can You Expect?

On September 19, 2016 the much-anticipated first wave of FSMA compliance dates arrived. Now larger food facilities must comply with Current Good Manufacturing Practice requirements (CGMPs) and meet certain preventative controls. In this article, Joann Givens – Co-chair of the FSMA Operations Team Steering Committee and director of FDA’s Food and Feed Program in the Office of Regulatory Affairs – answers a few questions about what business can expect about enforcement. Her simple advice: be proactive in addressing potential hazards.

FSMA is no longer a theoretical issue and it won’t be long until the FDA brings the enforcement hammer down on non-complying businesses. Is your facility ready? If not, we know how to help.

To read more, click here.

8/31/16: FDA Issues Initial Draft Guidance on FSMA Rules

On August 23rd, the Food and Drug Administration issued draft guidance for complying with the Hazard Analysis and Risk-Based Preventative Controls for Human Food regulation. While the draft isn’t yet complete, it does offer guidance for five of the 14 planned chapters, including:

  1. The Food Safety Plan
  2. Conducting a Hazard Analysis
  3. Potential Hazards Associated with the Manufacturing, Processing, Packing, and Holding of Human Food
  4. Preventative Controls
  5. Application of Preventive Controls and Preventive Control Management Components

While the deadlines for some of FSMA’s key requirements have been extended, the key dates impacting the refrigerated warehouse industry haven’t changed.

To read more, click here.

To read the draft guidelines, click here.

5/30/16: From Bonds to Burritos: How the Increasing Criminalization of Regulatory Offenses Affects the Food and Beverage Industry

In a recent post on the Food Safety Magazine website, Daniel Zinman and Alex Solomon – two white collar corporate lawyers – write about the Federal Government’s increased focus on enforcing food safety legislation and compared it to their recent crackdown on the banking industry.

Zinman and Solomon stress that food safety violations are no longer a matter of civil liability but are now being aggressively pursued by the Department of Justice as criminal violations. The DOJ is also using general mail and wire fraud charges against corporate violators as well as individuals. 

This should give every player in the food safety chain pause. Are you prepared to defend yourself against criminal charges brought by the United States? Few of us are. With the stakes higher than ever, it’s vital your food safety procedures are locked down. If you own a food storage facility, the best place to start is with the security of your building’s envelope.

To read more, click here.

5/22/16: Sanitary Transportation Rule Follows FSMA Preventive Model

Much has been said of the added responsibilities put on cold storage facilities in wake of the FSMA legislations, but did you know many of those same requirements also apply to the food transportation industry? A recent post on the Food Safety News blog explains many of these new requirements and reminds us that in many cases, it’s the shipper’s responsibility to ensure their transportation contractors are abiding by these rules. They include:

  •  Vehicles and transportation equipment must be suitable and cleanable for their intended use and must be capable of maintaining the proper temperature for safe transport.
  • The transportation operation must be sufficient to ensure food is kept at the correct temperature, ready-to-eat food will not be contaminated by raw foods, or contaminated by non-food items from previous loads.
  • Transportation personnel must be property trained (and the training must be adequately documented) in sanitary transportation practices.
  • Transportation firms must maintain proper and robust records of procedures, agreements, and training.

Is your shipper of choice up-to-date on FSMA requirements? If you don’t know, it’s probably wise to start that conversation today.

To read more, click here.

5/15/16: How the CDC Traced the Current Listeria Outbreak’s Source

No doubt you’ve heard about the most recent recall of frozen vegetables tainted with Listeria. The contaminated vegetables are part of over 350 product lines sold in some of the largest grocery retailers in the country. While these types of outbreaks are not new, the Centers for Disease control is utilizing new tools for tracking down contamination sources. By identifying and cataloguing whole genome sequences, CDC scientists were able to show this most recent outbreak is related to previous outbreaks in 2013 and 2015.

With the passage of FSMA and these new scientific tools, the federal government is focusing on food safety in unprecedented ways and it’s vital facility managers monitor their own products and buildings to ensure they’re abiding by these new guidelines.

To learn more about staying ahead of the FSMA curve, click here.

To read more about the CDC’s new diagnostic tools, click here and here.

2/14/16: 5 Steps to FSMA Compliance – Part 1

In November, 2015, Vapor Armour’s Eric Finnerty presented his technical paper Getting Ahead of the Curve: Preventing FSMA Violations, at the IACSC Conference in Las Vegas. Eric is the industry’s leading expert in mitigating the effects of ice and condensation in cold storage facilities and with the implementation of the new FSMA legislation, the topic is more important than ever. His 5 steps to FSMA compliance are the new blueprint for industry executives to follow. Here, we share part 1 of Eric’s paper.


Every facility faces ice and condensation contamination – even when it’s not visible. It lives inside the roof, walls, and insulation where it is not visible. Most facility personnel don’t realize it’s a problem until it comes to the surface. Many owners and directors refuse to even believe it’s a problem. Sometimes it happens quickly and sometimes it can take a while. All the interlocking components that make up your facility – different building materials, climate, internal temperatures – are working to create holes in your vapor barrier. When your building envelope allows condensation, food gets contaminated, and the FDA and OSHA fine you. Furthermore, with the new Food Safety Modernization Act (FSMA) already in force, the penalties are only going to increase. It doesn’t have to be this way.

Step 1: Understanding Air Movement

Though it may be invisible, the air around us is made up of tiny molecules of oxygen and nitrogen that move based on their temperature. Warm molecules jump around, colliding with one another in an energized frenzy. Cold molecules are more relaxed, moving with less energy and colliding less often. This is the starting point in understanding how air flows from one area to another.

Those fast moving particles don’t want to stay in one place. As air warms, it rises and as it cools it falls, and because nature hates a vacuum, whenever warm air does rise, cold air moves in to replace the air that’s just left. This cycle continues endlessly across the face of the earth and is impacted by geography, moisture, population density, and even the rotation of the earth. By it’s nature, air is a traveller but it’s always taking directions from an external force.

Taken to the extreme, this movement of air is seen in the most intense forest and wildland fires. As flames burn timber and undergrowth to char, the molecules in the air directly above the fire become superheated and rush upwards. At the same time, cooler air from outside the fire rushes in to take the place of the heated, rising air, creating wind flowing back towards the flames.

Hurricanes also form under the same principle. Warm, moist air rises, cools, condenses and flows away from areas of high pressure. The largest storms possess the largest areas of high pressure which drive the 3 largest amount of air towards lower pressure areas and form the high winds associated with the most destructive weather systems. It’s a natural phenomenon that is happening in every thermal controlled building in the world where the problem has not been addressed properly.

Read the entire paper here.

2/11/16: Why Ice Forms in Thermal Controlled Cold Storage Freezers

Do you wonder why ice and condensation form in your cold storage facility? Do you believe it’s a problem with no real solution? Watch as Eric Finnerty, Vapor Armour President, explains how vapor drive creates ice and condensation and how Vapor Armour is the solution you didn’t know you needed.

Watch more content on the Vapor Armour YouTube Page.

2/3/16: The Troubling Problem for the Fresh Produce Industry

The journal Food Safety News recently published an in-depth article about the unique threat the fresh produce industry faces from Listeria contaminations. In short, the pathogen thrives in cool, damp environments and it takes as few as 1,000 cells to cause disease. According to the authors, management controls are the key to preventing Listeria outbreaks

“The keys to prevention of Listeria are vigilance and management oversight, and making the right decisions. Upper management involvement in sanitation problems is critical, along with management support for needed capital improvements in facilities that have issues. Furthermore, sufficient resources must be applied to the frequent and ongoing monitoring of the environment and the verification of sanitation.”

Because deficient building envelopes are often the cause of ice and condensation issues, and because moisture is an ideal breeding ground for Listeria, executives who want to stay ahead of contamination issues would be wise to seal up their cold-storage facilities. Installation of Vapor Armour will stop warm air infiltration, eliminate excess moisture, and reduce the risk of food contamination. Contact us today for more information.

Read More Here

1/31/16: Should You Worry About Listeria-Related Food Recalls?

Here’s a great blog post explaining the Listeria bacteria and why it’s become such a threat to food safety. Food Scientist Kantha Shelke, Ph.D., has this to say about what consumers can do to avoid becoming infected by Listeria:

“There is little an average cantaloupe-eating, ice cream cone-ordering consumer can do besides adhering to proper food preparation hygiene and buying from manufacturers and retailers who have high standards of cleanliness,”

That’s sobering news for consumers and should act as a call-to-action to everyone in the food supply chain. The responsibility to prevent sickness lies with food handlers and controlling ice and condensation issues in cold-storage facilities is vital in preventing the spread of this deadly bacteria.

Read More Here

1/27/16: Consumers Call for More Food Safety Monitoring

According to Food Business News, a recent national study found that 74% of consumers believe fast food companies should monitor food safety more closely. This new information comes in the wake of Chipotle’s continuing problems with E. coli contamination in their restaurants nationwide.

These contamination issues are often tracked back to problems within distribution environments and that’s a big reason why the FDA is now so concerned with eliminating ice and condensation within the cold storage industry. For distributors this all starts with a sealed building envelope. To learn more about how Vapor Armour can help, contact us today.

Read More Here

1/20/16: Legal Woes Highlight Dangers of the Food Industry Supply Chain

A report in The National Review recaps the recent surge in food safety scandals and examines the Federal Government’s increased focus on prosecuting executives and managers who are aware of safety issues but choose not to address them.

From the article:

“In September, the Justice Department finalized a landmark conviction of the former head of the Peanut Corporation of America, who was sentenced to 28 years in prison for knowingly shipping salmonella-tainted products that sickened 714 people and killed nine. That may be the department’s first step in a new approach to taking food industry product safety more seriously, and more aggressively pursuing wrongdoing on a criminal level. The Justice Department has now opened formal investigations into the e. coli outbreak at Chipotle and the listeria outbreak at Blue Bell Creameries, both of which sickened hundreds of consumers.”

And it’s not just violations in your direct control. The Feds are also holding executives accountable for lapses that occur further down the supply chain. This is just another reminder that ignoring FSMA provisions can have devastating consequences.

Read more here

1/18/16: DOJ Probing Executives Over Listeria Outbreak

The stakes keep getting higher for executives in the food storage industry. New reports suggest the Department of Justice is investigating Blue Bell Ice Cream’s handling of the their 2015 Listeria outbreak and what company executives new about their facility’s contamination risks beforehand. This is more proof that the Federal Government’s new focus on food safety will include criminal consequences for those who choose to ignore its provisions.

Read more here