Food Safety

05 Nov

FDA’s 2026 Food Code: What Companies Need to Know

The Food and Drug Administration (FDA) released the 2026 Food Code on September 17, 2026, updating the food safety framework for retail food stores, food service establishments, and food vending operations. The Food Code provides a model for safeguarding public health and ensuring that food offered to consumers is unadulterated and honestly presented. The 2026 edition emphasizes preventive management and documented controls, while updating provisions for food defense, employee illness, allergen cross-contact, sanitation, and specialized processes.

Key Changes and Updates

FDA’s Food Code does not automatically carry the force of law nationwide; state, local, tribal, territorial, and federal authorities determine whether, when, and how to adopt it. Companies should therefore:

Monitor applicable requirements, amendments, and effective dates.
Assess how the 2026 changes affect each location.
Consider a companywide baseline for multi-site operations.

The table below summarizes the primary changes and practical steps companies can take to prepare.

Area	Update	Recommended Actions
Stronger Preventive Management	The Code defines “Food Defense” and “Food Safety Management System,” adds food defense to person-in-charge knowledge and employee training requirements, and requires covered establishments to implement a written food safety management system (FSMS) within four years of adoption. The system must be available to regulators; minimal-risk establishments may be exempted.	Track adoption dates and affected locations. Establish documented hazards, controls, monitoring, corrective actions, verification, records, responsibilities, and food defense training. Retain implementation evidence and confirm any low-risk exemption.
Written Employee Illness Policies	Permit holders must maintain a written employee illness policy. Employees must understand reporting duties; managers must apply exclusion, restriction, response, reinstatement, and documentation requirements, while protecting health information.	Development/update the policy, reporting channels, decision criteria, return-to-work process, and confidential records, as necessary. Train employees and individuals in charge on reportable symptoms, diagnoses, exposures, exclusions, restrictions, and notifications; verify consistent application.
Updated Hand-Contact and Refill Controls	The Code permits double gloving only under specified conditions; handwashing and required glove changes still apply. It also clarifies safeguards for refilling employee- or consumer-owned containers without contaminating food, equipment, utensils, or premises.	Define when double gloving and refilling are allowed, required handwashing and glove-removal steps, container inspection or cleaning, approved refill methods, and contamination controls. Train employees and verify practices.
Cooling and Specialized Processes	The Code establishes an alternative retail cooling process and adds/clarifies provisions for sushi rice acidification, dehydration, freeze-drying, reduced-oxygen packaging, and related specialized processes.	Identify affected processes and confirm scientific support, critical limits, monitoring, corrective actions, verification, records, equipment capability, and employee competency. Obtain required approval, Hazard Analysis and Critical Control Points (HACCP) Plan acceptance, or a variance before implementation.
Allergen Controls and Consumer Information	The Code clarifies allergen cross-contact controls and revises consumer advisory requirements for applicable raw or undercooked animal foods.	Review recipes, supplier information, menu advisories, order entry, preparation sequencing, equipment and utensil controls, cleaning verification, and allergy-request escalation. Update training and confirm jurisdiction-specific advisory wording and placement.
Sanitation, Disinfection, and Facility Controls	The Code addresses sanitizer temperatures and equipment and utensil disinfection, classifies disinfectants as poisonous or toxic materials, and updates requirements for waste receptacles, water-based fire protection systems, and vending machines.	Validate chemical concentrations, temperatures, contact times, labeling, storage, and equipment compatibility. Update procedures and logs; inspect waste, fire protection, and vending controls; correct gaps; and train employees on safe use and verification.
Expanded Definitions and Operational Clarifications	The Code defines “Mobile Food Establishment” and “Water-Based Fire Protection Systems,” clarifies that commissaries are food establishments, and revises provisions for toxic materials, food donations, specialty mushrooms, refillable containers, and inspection reports.	Map affected operations and records to the revised definitions. Confirm permit coverage and responsibilities, update standard operating procedures (SOPs) and inspection-readiness checklists, and address jurisdiction-specific amendments before implementation.

Implications for Food Companies

As jurisdictions adopt applicable provisions, companies should expect greater scrutiny of written policies, process controls, training records, and evidence that required monitoring is consistently completed.

Individuals in charge must be able to demonstrate how food safety risks are identified, monitored, corrected, and verified during normal operations. For specialized activities, including mobile operations, commissaries, refill programs, freeze-drying, dehydration, acidified rice preparation, and alternative cooling methods, this may require closer review, revised plans, or consultation with regulatory authorities.

For multi-site operators, a companywide baseline can provide consistency while allowing procedures, records, and implementation schedules to reflect jurisdiction-specific requirements.

What Companies Should Do Now

Companies can begin preparing before formal adoption by identifying affected operations, prioritizing higher risk gaps, and developing the policies, controls, training, and records needed for implementation.

Track adoption and transition periods. Identify the Food Code edition currently adopted in each operating jurisdiction, monitor pending rulemaking and local amendments, and record all delayed effective dates. Include the four-year implementation period for the written FSMS, measured from the regulatory authority’s adoption of the 2026 Food Code.
Complete a gap assessment. Compare current policies and practices with FDA’s summary of changes and the full 2026 Food Code, then confirm the requirements adopted in each jurisdiction. Prioritize the updates related to employee illness, allergens, cooling, glove use, disinfection, and specialized processes.
Update controls and records. Define responsibilities, monitoring procedures, corrective actions, verification activities, and recordkeeping requirements.
Revise employee health procedures. Update the written policy, reporting process, management response, training, and confidential recordkeeping practices.
Validate specialized processes. Confirm scientific support and any approval or variance requirements before implementation.
Strengthen allergen and sanitation programs. Review cross-contact prevention, consumer communication, cleaning, disinfection, chemical use, and verification practices.
Train by role and verify competency. Tailor training to job responsibilities and confirm understanding through observation, records, or demonstration.
Assess inspection readiness. Test implementation during normal operations and correct gaps before an inspection.

The 2026 Food Code signals a shift toward stronger preventive management, clearer written controls, and greater evidence that procedures work during normal operations. Beginning before local deadlines will give companies time to resolve higher risk gaps and strengthen the controls employees rely on every day.

22 Oct

Food Safety

Comments: No Comments

USDA-FSIS Expands Listeria Sampling at RTE Facilities

The U.S. Department of Agriculture’s Food Safety and Inspection Service (USDA-FSIS) is expanding its Listeria environmental sampling program nationwide. Beginning in January 2027, federal inspectors will add routine swabbing of food contact and non-food contact surfaces when collecting samples of post-lethality exposed ready-to-eat (RTE) products. RTE meat and poultry facilities should be prepared to demonstrate that their environmental monitoring, sanitation, and corrective action systems are not only documented but effective in practice.

What FSIS Is Changing

Under the expanded approach, inspection program personnel will collect four environmental swabs whenever they collect an existing post-lethality exposed RTE product sample through the RTE Product Sampling (RTEPROD) project in the Public Health Information System (PHIS). The set will include two food contact surface swabs and two non-food contact surface swabs, all analyzed for both Listeria monocytogenes (Lm) and other Listeria species.

FSIS has stated that the national program will use the same swabbing procedures, laboratory methods, reporting, and follow-up actions as its Routine Risk-Based Listeria monocytogenes (RLm) Sampling and Intensified Verification Testing programs.

The expansion does not create a new facility testing requirement. Instead, it gives FSIS more frequent insight into sanitation conditions on and around processing lines by pairing environmental swabs with an existing product sampling event. This approach broadens the agency’s view of processing conditions without creating a separate sampling visit or extending product holds beyond those associated with the existing event. Federal sampling will supplement, not replace, the facility’s Environmental Monitoring Program (EMP).

What Expansion Means for Food Companies

For food companies, the expanded program increases the likelihood that environmental conditions, sanitation practices, and corrective action systems will be evaluated alongside routine product sampling. Facilities should expect greater attention on how effectively they identify and address potential Listeria harborage, analyze recurring findings, and document evidence of control.

The following areas are likely to receive increased attention as FSIS expands environmental sampling:

Sanitation controls will face more frequent verification. Routine federal swabbing of food contact and non-food contact surfaces may reveal conditions that product testing alone does not detect. The expanded program may also increase scrutiny of equipment and nearby environmental areas that inspection personnel identify as potential harborage or transfer points.
Findings of other Listeria species will still matter. Even when Lm is not detected, other Listeria species may indicate sanitation deficiencies or potential harborage. Companies should evaluate trends and recurring findings through their EMP and corrective action systems and be prepared to demonstrate that their responses were effective.
A positive Lm result may broaden the investigation. FSIS conducts whole genome sequencing on Lm-positive isolates and compares the results with reported illnesses and historical findings. Depending on those comparisons and other evidence, the agency may conduct intensified sampling, examine sanitation and hazard control records more closely, pursue regulatory follow-up, or evaluate the scope of implicated product and related operational consequences.
Documentation should show that controls are consistently executed on the plant floor. Records should demonstrate that sampling sites are selected based on risk, results are reviewed promptly, recurring positives are investigated to determine root cause, corrective actions are verified, and senior leaders are notified when trends indicate a potential loss of control.

Implementation Timeline and Facility Preparation

The national expansion follows a fiscal year (FY) 2026 pilot in the Alameda, Chicago, and Raleigh districts and incorporates lessons from agency investigations of 2024 listeriosis outbreaks associated with FSIS-regulated products. FSIS will fully implement the sampling program by district according to the following schedule:

January 2027: Alameda and Atlanta districts
February 2027: Raleigh, Springdale, and Denver districts
March 2027: Chicago, Philadelphia, Des Moines, and Dallas districts

Facilities should use the period before implementation reaches their district to complete the following readiness actions:

Reassess the facility’s EMP. Confirm that sampling sites cover food contact surfaces and meaningful non-food contact niches across hygienic zones, shifts, lines, and operating conditions. Use rotating and risk-based sites rather than relying on an unchanged list.
Conduct a focused “seek-and-destroy” assessment. Examine equipment design, hollow framework, seals, conveyors, slicers, drains, floors, condensation points, employee and equipment traffic patterns, and areas that are difficult to access or clean. Correct conditions that allow moisture, residue, or microbial harborage to persist.
Stress-test sanitation verification. Observe pre-operational and operational sanitation, verify chemical concentrations and contact times, assess cleaning sequences and tools, and confirm that equipment is disassembled sufficiently. Close findings only after corrective actions have been shown to be effective.
Analyze historical data for patterns. Trend results by organism, site, zone, line, product, shift, date, and corrective action. Look beyond individual negative or positive results to identify recurring locations, seasonal patterns, and movement between non-food contact and food contact areas.
Strengthen the response plan. Define who must be notified, how potentially affected product will be identified and controlled, when expanded vector sampling will begin, how root cause will be documented, and what evidence will be required before normal operations resume.
Review the Listeria control program against actual practice. Confirm that the facility’s hazard analysis, sanitation standard operating procedures (SSOPs), supporting documentation, testing program, and chosen Listeria Rule alternative remain accurate and consistent with current operations.
Prepare inspection-facing records. Organize recent environmental and product results, trend analyses, sanitation records, maintenance work orders, corrective actions, validation or supporting documentation, and employee training records so they can be retrieved and explained promptly.
Train the response team. Ensure that quality, sanitation, operations, maintenance, warehousing, and leadership personnel understand how to support FSIS sampling, protect sample integrity, manage product status, communicate clearly, and avoid making ad hoc decisions.

FSIS’s nationwide rollout will make environmental swabbing a routine component of post-lethality exposed RTE product sampling, giving the agency greater visibility into conditions that may allow Listeria to persist or spread. Readiness for this initiative will require more than just written programs: sampling design, sanitation practices, trend analysis, escalation procedures, and records must demonstrate effective control in daily operations.

Facilities should treat the phased rollout as a deadline for conducting a documented readiness review and converting identified gaps into corrective actions with a responsible owner, due date, and effectiveness check. Addressing those gaps now will strengthen Listeria control and help facilities respond in a more organized, evidence-based manner when expanded sampling begins.

10 Sep

Food Safety

Comments: No Comments

FDA Finalizes Updated Fresh-Cut Produce Guidance

Ready-to-eat (RTE) fresh-cut produce is convenient and widely consumed, but it also presents elevated food safety risk. Because these products are distributed fresh and generally do not undergo a kill step, the risk of contamination across the supply chain is significant, whether during growing and harvesting, transportation, manufacturing, commingling, retail handling, or even consumer use. Recent outbreaks and recalls due to fresh-cut produce contamination reinforce the potential magnitude of this concern.

The Food Safety Modernization Act (FSMA) Current Good Manufacturing Practice, Hazard Analysis and Risk-Based Preventive Controls for Human Food (PSHF) rule requires fresh-cut produce operations to follow current Good Manufacturing Practices (cGMPs) and implement risk-based preventive controls. To help manufacturers and processors comply with the PCHF rule, the Food and Drug Administration (FDA) recently announced an update to its Guide to Minimize Biological Hazards in Ready-to-Eat Fresh-Cut Produce, originally published in 2008.

Guidance for Compliance

Fresh-cut produce includes fruits and vegetables that have been physically altered from their whole state (e.g., chopped lettuce, cut melon, diced onions, shredded carrots, peeled fruit, or trimmed vegetables) and distributed in fresh form without additional processing. This cutting, peeling, coring, shredding, or trimming can expose nutrient-rich internal tissues, create surfaces where microorganisms can attach and grow, and spread contamination from one item or surface to many others during processing.

The risk is amplified because many fresh-cut products are ready-to-eat (RTE) and do not undergo a lethality treatment (or kill step) before they reach consumers. Once introduced, pathogens can persist in equipment niches, biofilms, drains, standing water, employee traffic patterns, and other areas of the processing environment.

FDA’s updated 2026 guidance translates the PCHF rule framework into practical controls for fresh-cut produce. The core message is straightforward: processors must rely on strong preventive systems, supported by documented monitoring, verification, and corrective action, to minimize biological contamination.

Key Provisions and Expectations

FDA’s updated guidance aligns fresh-cut produce operations with cGMP and Hazard Analysis and Risk-based Preventive Controls (HARPC) requirements in 21 CFR Part 117. For RTE fresh-cut produce, the emphasis is on integrated controls that reflect the product, process, facility environment, and intended use. Facilities should evaluate reasonably foreseeable hazards, determine which hazards require preventive controls, and implement written controls with monitoring, corrective actions, verification, validation where appropriate, and records, as follows:

Food Safety Plan: Develop, implement, and maintain a written plan that identifies hazards (primarily biological), preventive controls, monitoring procedures, corrective actions, verification activities, and recordkeeping.
Hazard Analysis: Evaluate the product, ingredients, process steps, equipment, facility layout, intended use, storage conditions, and likelihood that consumers will eat the product without further processing.
Sanitation Controls: Address cleaning and sanitizing of food-contact surfaces, prevention of cross-contamination, hygienic zoning, employee practices, glove and utensil controls, traffic flow, and management of drains and wet areas.
Supply Chain Controls: Verify that suppliers adequately control hazards in raw produce and other ingredients when those hazards are controlled before receipt.
Process and Temperature Controls: Use refrigeration, time limits, wash water controls, and other validated parameters to minimize pathogen growth and cross-contamination.
Environmental Monitoring: Use risk-based monitoring where RTE product is exposed to the environment and contamination with environmental pathogens is a reasonably foreseeable hazard.
Corrective Actions and Verification: Investigate deviations, prevent affected product from entering commerce when safety is uncertain, verify that controls are operating as intended, and maintain complete records.

Best Practices and Key Actions

FDA’s guidance is most useful when translated into daily operating practices. Fresh-cut produce processors and manufacturers should leverage the guidance to evaluate whether preventive controls are built into each point where product, people, equipment, water, and the processing environment can introduce or spread contamination.

1. Strengthen Raw Material and Supplier Controls. Fresh-cut produce safety begins before the product reaches the processing line. Manufacturers should maintain supplier approval programs that consider growing practices, harvest conditions, water sources, field sanitation, transportation, prior supplier performance, and relevant outbreak or recall history. Receiving procedures should include lot identification, condition checks, temperature checks where applicable, and documentation that supports traceability.

Key actions: Update the hazard analysis by commodity and intended use; verify supplier approval criteria, incoming lot records, audit or certificate documentation where used, and supplier corrective action history.

2. Control Water as a Potential Vehicle for Cross-Contamination. Water management is one of the most important controls in a fresh-cut produce facility. Wash and process water can reduce surface contamination when properly controlled, but unmanaged water can also move pathogens quickly across lots, equipment, and finished product contact areas. Water used for washing, cooling, fluming, ice, equipment cleaning, and employee hygiene must be managed to prevent it from becoming a contamination source.

Key actions: Define water quality expectations; confirm water quality standards, antimicrobial levels where used, monitoring frequency, corrective actions, documentation, and any temperature or organic-load limits (turbidity) needed to prevent cross-contamination; document corrective actions when parameters fall outside established limits.

3. Design Sanitation Programs Around Product Exposure. Sanitation programs need to reflect how fresh-cut produce is actually exposed during production. Because cutting and handling create more product contact surfaces, sanitation procedures should focus on both visible soil removal and the less obvious niches where microorganisms can persist. Effective programs include defined cleaning frequencies, validated cleaning methods, sanitizer concentrations and contact times, pre-operational inspections, ATP or microbiological verification as appropriate, and heightened attention to hard-to-clean areas (e.g., slicers, dicers, peelers, conveyors, hollow rollers, gaskets, drains, floors, splash zones, and equipment framework).

Key actions: Verify that cleaning procedures reach equipment niches, sanitation frequencies are risk-based, post-sanitation inspections are documented, and maintenance-related sanitation controls are effective.

4. Use Hygienic Zoning and Traffic Controls. Hygienic zoning provides the structure to keep controls consistent across shifts, products, equipment changes, and maintenance activities. Processors should separate raw, in-process, and RTE exposure areas to prevent transfer of pathogens through people, equipment, tools, air, water, condensation, forklifts, totes, and maintenance activities. Where physical separation is not possible, facilities should establish procedural barriers (e.g., dedicated tools, color coding, footwear controls, handwashing and glove-change requirements, controlled employee movement, and documented sanitation after maintenance or production interruptions).

Key actions: Map product and personnel flow to identify crossover points, splash risks, shared tools, employee movement patterns, and opportunities for raw-to-RTE contamination; reinforce training on handwashing, glove use, illness reporting, traffic controls, and escalation procedures.

5. Build a Robust Environmental Monitoring Program (EMP). Environmental monitoring verifies whether sanitation and zoning controls are working as intended. In RTE fresh-cut produce areas, a well-designed EMP should identify patterns, recurring risks, areas of concern, and opportunities to strengthen controls before product safety is affected. The EMP should define the test organism, sampling zones, number and location of sites, timing, frequency, analytical method, laboratory, corrective action procedures, and trend review. Positive findings should trigger timely investigation, intensified cleaning, resampling, and evaluation of whether product may have been affected.

Key actions: Strengthen environmental monitoring by using trend data to identify recurring sites, persistent organisms, sanitation weaknesses, maintenance-related risks, and conditions requiring corrective or preventive action.

6. Maintain Temperature Control Through Distribution. Temperature control extends food safety beyond production to transportation, storage, retail handling, and consumer-facing conditions. Because many fresh-cut products support microbial survival or growth, refrigeration and time control are critical. Facilities should define temperature limits for receiving, processing, storage, and distribution; monitor those limits; evaluate deviations; and coordinate with carriers and customers to prevent temperature abuse after product leaves the facility.

Key actions: Verify receiving, processing, storage, and distribution temperature limits; evaluate deviations; coordinate expectations with carriers and customers; test traceability and recall readiness through mock recalls.

Bottom Line

FDA’s 2026 updated guidance reinforces that fresh-cut produce safety depends on prevention, not end-product correction. For manufacturers and processors, the priority is to use the guidance to evaluate whether the Food Safety Plan is both adequate for an RTE, no-kill-step product and fully implemented throughout the facility. Processors and manufacturers that do so will be better positioned to reduce biological risk, strengthen compliance, and protect consumers.nforces that fresh-cut produce safety depends on prevention, not end-product correction. For manufacturers and processors, the priority is to use the guidance to evaluate whether the Food Safety Plan is both adequate for an RTE, no-kill-step product and fully implemented throughout the facility. Processors and manufacturers that do so will be better positioned to reduce biological risk, strengthen compliance, and protect consumers.

19 Aug

Food Safety / Information Management Solutions

Comments: No Comments

Tech Corner: KTL Assessment App

All types of organizations and operational processes demand a variety of audits and assessments to evaluate compliance with requirements, ranging from government regulations, to industry codes, to management system standards (e.g., ISO, GFSI), to internal obligations. Audits and assessments capture regulatory compliance status, management system conformance, supplier compliance, adequacy of internal controls, potential risks, and best practices. In short, audits and assessments are essential for improving and verifying compliance performance, internal controls, potential risks, and best practices.

Having the right tool for the job can make audits significantly more efficient. This includes the protocol and templates developed as part of pre-audit preparation, as well as audit/assessments tools that may be used to conduct and manage audits more efficiently and effectively. The KTL Assessment App is a comprehensive audit management solution built on the Microsoft Power Platform and Dataverse that enables organizations to more efficiently create, manage, and execute audits, while managing and tracking corrective actions.

Functionality: What does it do?

KTL’s Assessment App supports the entire audit lifecycle. Users can conduct audits and assessments from desktop or mobile devices, record responses, capture comments, attach photos, track progress, and assign corrective actions. The app features a fully customizable framework that enables organizations to build robust audit programs tailored to their specific regulatory, operational, and business requirements.

The solution works through three applications:

Assessment Report App: The Assessment Report App allows managers to review audit findings and manage corrective actions. The application supports PDF report generation and sharing to improve communication and compliance documentation.
Assessment Management App: The Assessment Management App serves as the administrative hub. Administrators can create and manage assessment templates, data, and configuration settings.
Assessment App: The Assessment App is the primary user-facing application used to conduct audits and assessments. Available on desktop and mobile devices, it allows auditors to view audits, answer questions, upload supporting evidence, and track progress. Scoring and progress tracking provide real-time insight into assessment progress.

Benefits: Why do you need it?

KTL’s Assessment App helps organizations manage audits and assessments more consistently, efficiently, and transparently. By centralizing setup, execution, reporting, and corrective action tracking, the app improves visibility into audit status, strengthens accountability, and supports better compliance decision-making.

Program setup and administration: Add and manage users, locations, standards, audit types, assessment templates, and scoring models.
Audit execution: Record responses, comments, and supporting evidence; monitor assessment progress and completion status in real time; and automatically calculate scores throughout the audit process.
Reporting and decision support: Generate reports and PDF summaries that support compliance reviews and provide management with clear information for decision-making.
Corrective action management: Track corrective actions to ensure findings are assigned, addressed, and resolved.
Data security: Protect assessment data through role-based access controls and permissions.

With assessment management, automation, reporting, and corrective action tracking in one platform, KTL’s Assessment App gives organizations a more reliable way to manage audit programs, capture compliance status, identify trends, and drive continuous improvement.

Technology Used

Dataverse
Power Apps
Power Automate

19 Aug

Environment / Food Safety / Information Management Solutions / KTL News / Quality / Safety

Comments: No Comments

Don’t Miss KTL at the WCA Annual Training Conference

KTL will be exhibiting at the Wisconsin Correctional Association’s (WCA) 2026 Annual Training Conference in Wisconsin Dells September 20-22, 2026. WCA hosts this annual statewide conference to bring together correctional professionals, students, and leaders across the criminal justice system. The event supports collaboration, professional development, and meaningful dialogue around the future of corrections.

Be sure to stop by and visit KTL at our exhibit booth (#18). We’ll be sharing more about our EHS, food safety, and Microsoft 365 information management solutions. We look forward to connecting with you in the Dells!

18 Aug

Food Safety

Comments: No Comments

Q&A with the Expert: Demystifying FSSC 22000 and ISO 22000

Food Safety System Certification (FSSC) 22000 is a robust Global Food Safety Initiative (GFSI)-recognized food safety certification scheme based on ISO 22000 that is applicable across the food chain (i.e., food/feed manufacturing, packaging production, transport, and storage). As a certification scheme, FSSC 22000 is unique in that it comprises three separate elements:

ISO 22000 International Standard – Specifies requirements for a food safety management system (FSMS) in alignment with the ISO Harmonized Structure.
ISO/Sector-Specific Technical Specifications (TS) 22002 – Requires organizations to establish Prerequisite Programs (PRPs) for specific sectors.
FSSC 22000 Scheme Additional Requirements – Provides comprehensive additional requirements that build on ISO 22000 and sector-specific PRPs.

With recent updates to the FSSC 22000 Scheme (i.e., Version 7) and ISO/TS 22002, as well as planned updates (2027) to the ISO 22000 Standard, there is a lot of confusion surrounding applicable requirements, how they are related, and compliance timelines. KTL’s Q&A with our food safety experts helps clarify some of the commonly asked questions regarding ISO 22000 and FSSC 22000.

How do ISO 22000 and FSSC 22000 work together?

ISO 22000 is an internationally recognized FSMS standard for any organization in the food chain, regardless of size or role. It combines management system practices, risk-based thinking, PRPs, interactive communication, and Hazard Analysis and Critical Control Points (HACCP) principles to help organizations identify, prevent, control, and continually improve how they manage food safety hazards.

FSSC 22000 is a food safety certification scheme built on ISO 22000. It includes ISO 22000, applicable sector-specific PRP standards (ISO/TS 22002), and FSSC 22000 Additional Requirements. The scheme is managed by Foundation FSSC and is benchmarked by GFSI, which is why many global brands, retailers, manufacturers, and buyers recognize or require it.

ISO 22000 provides the core FSMS framework and can stand on its own. In turn, FSSC 22000 uses that framework as its foundation and adds a more prescriptive certification structure. In practical terms, a company with a well-implemented ISO 22000 system has already built much of the foundation needed for FSSC 22000, but it must still address the applicable PRP standard, FSSC Additional Requirements, scheme rules, audit expectations, and certification body requirements.

What is the main difference between ISO 22000 and FSSC 22000?

ISO 22000 and FSSC 22000 are closely connected, but they are not interchangeable. The main differences between the standards are related to certification scope and market recognition. ISO 22000 defines what an organization must do to control food safety hazards across the food chain. FSSC 22000 builds on ISO 22000 by adding sector-specific PRP requirements, FSSC Additional Requirements, scheme rules, and GFSI-recognized certification used to satisfy major customer, retailer, and procurement expectations. This includes additional requirements for areas such as food defense, food fraud mitigation, allergen management, environmental monitoring, equipment management, and food safety and quality culture.

What does my facility need to do to comply with the three elements of FSSC 22000?

To comply with FSSC 22000, a facility must implement all three elements (i.e., ISO 22000, ISO/TS 220002, FSSC 22000 Additional Requirements) as one integrated FSMS, not as separate documents or checklists, as follows:

ISO 22000: Define the FSMS scope; assign leadership responsibilities; identify internal and external risks; establish food safety objectives; complete hazard analysis; define PRPs, operational prerequisite programs (OPRPs), and critical control points (CCPs); control monitoring and corrective actions; maintain traceability and recall processes; conduct internal audits; complete management review; and drive continual improvement.
ISO/TS 22002: Identify and implement applicable sector-specific PRP requirements from the ISO 22002 series; translate the relevant TS into site controls for areas such as zoning, facility design, equipment, cleaning and sanitation, pest management, utilities, personnel hygiene, storage, transport, waste handling, maintenance, supplier controls, and prevention of cross-contamination; verify that these PRPs are effective, current, and supported by records, not just written into procedures.
FSSC 22000 Scheme Additional Requirements: Meet applicable requirements for purchased services and materials, product labeling, food defense, food fraud mitigation, allergen management, environmental monitoring, equipment management, food safety and quality culture, quality control, transport and delivery, and any other requirements that apply to the facility’s food chain category and certification scope.

A documented gap assessment against ISO 22000, the applicable ISO/TS 22002 PRP standard, and the FSSC 22000 requirements is a practical place to start. Facilities can then work to convert the gaps into an implementation plan with assigned responsibilities, training, verification activities, internal audit checks, and management review follow-up to ensure effective implementation.

What are the recent changes to the ISO/TS 22002 PRPs?

The ISO/TS 22002 series was modernized in 2025. The new structure introduces ISO 22002-100 as a common baseline for food, feed, and packaging supply chains, supported by sector-specific parts to create a more consistent PRP framework and help simplify implementation for organizations operating across multiple sectors. Sector-specific categories are defined as follows:

ISO/TS 22002-1: Food Manufacturing
ISO/TS 22002-2: Catering
ISO/TS 22002-3: Farming
ISO 220002-4: Food Packaging
ISO/TS 22002-5: Transport and Storage
ISO/TS 22002-6: Feed and Animal Food Production
ISO/TS 22002-7: Retail and Wholesale Operations
ISO/TS 22002-100: Common/General Requirements

With this change, every certified facility must now comply with ISO/TS 22002-100, which consolidates general, common requirements across the entire supply chain, while also implementing their sector-specific requirements. The ISO/TS 22002 updates also demand tighter focus related to hygienic design and zoning, material and chemical control, and allergen and environmental monitoring.

The release of the restructured ISO/TS 22002:2025 series serves as the primary driver behind the creation of FSSC 22000 Version 7 (V7). As such, the timeline for compliance with the ISO/TS 22002:2025 series is tied directly to the FSSC 22000 transition to V7. See below.

What is changing in FSSC 22000 V7?

In early May 2026, Foundation FSSC published V7 of the FSSC 22000 Scheme Additional Requirements. It aligns the scheme with the updated ISO/TS 22002:2025 PRP series and GFSI benchmarking requirements, updates food chain categories, strengthens select Additional Requirements, and introduces a new requirement related to sustainable packaging design principles for organizations involved in packaging design or packaging material changes. V7 also updates auditor qualification requirements and transition expectations.

FSSC has established a phased transition from V6 to V7. Audits against V6 are allowed only up to April 30, 2027. Updated audits against V7 are expected to take place from May 1, 2027 through April 30, 2028. Again, this includes the updated ISO/TS 22002:2025 requirements.

What changes are expected for ISO 22000 in 2027?

ISO 22000:2018 remains the current certifiable edition, but a revised ISO 22000 standard is anticipated in 2027. The revision is expected to strengthen food defense, food fraud, and food safety culture; clarify the relationship between CCPs, OPRPs, and PRPs; and support alignment with the updated ISO/TS 22002 PRP series.

Should I wait for ISO 22000:2027 before pursuing certification?

No. Companies should continue to implement, maintain, and improve their systems against the currently applicable requirements. Waiting for the updated ISO 22000 standard may delay customer approvals, weaken audit readiness, and create a larger transition burden later. Organizations should focus on the changes associated with FSSC 22000 V7 and ISO/TS 22002 and strengthening core FSMS disciplines, including hazard analysis, PRP effectiveness, traceability, management review, internal auditing, corrective action, supplier approval, food defense, food fraud mitigation, and food safety culture.

What should I do now?

With ISO/TS 22002 and FSSC 22000 V7 now released and ISO 22000 expected to be revised in 2027, food companies should use the transition period to modernize PRPs, strengthen intentional risk controls, make food safety culture measurable, and prepare evidence that their food safety system works in practice:

Map your current system against the applicable requirements. Conduct a clause-by-clause and process-by-process gap assessment. This should include ISO 22000, the relevant ISO/TS 22002 PRP standard, FSSC 22000 V7 Additional Requirements. Identify gaps that need to be addressed to meet the updated requirements.
Plan the FSSC 22000 V7 transition early. Build a transition plan based on the gap assessment that includes document updates, PRP revisions, personnel training, internal auditor training, supplier communication, validation or verification activities, internal audits, management review, and certification body scheduling.
Update PRPs using the new ISO/TS 22002 structure. Review sanitation, zoning, personnel hygiene, utilities, pest control, maintenance, supplier controls, waste handling, storage, transport, and other PRP elements against the updated ISO 22002-100 baseline and the relevant sector-specific part. Multisite or multisector companies should coordinate shared PRPs while preserving site-specific controls.
Strengthen intentional risk programs. Food defense and food fraud are becoming increasingly prominent in both FSSC 22000 and the expected ISO 22000 revision. Maintain documented threat and vulnerability assessments, define mitigation measures, verify controls, and review these programs when products, suppliers, materials, processes, or geopolitical risks change.
Make food safety culture auditable. Food safety culture should be a lived organization value. Define leadership expectations, employee behaviors, communication methods, training needs, escalation practices, and measurable indicators. Use internal audits, management review, employee feedback, and corrective action trends to show that food safety responsibilities are understood and practiced throughout the organization.

14 Jul

Food Safety / Quality

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Managing Food Safety Risks in Warehouse and Distribution Centers

Recent recalls tied to contaminated warehouse conditions show how quickly an outside storage or distribution failure can become a brand, consumer safety, and regulatory problem for any company whose products pass through that facility. Food safety and quality are not limited to food manufacturers. When a third-party logistics (3PL) provider, outside warehouse, wholesaler, or distribution center (DC) stores regulated products under unsanitary conditions, otherwise compliant products can become adulterated after they leave the manufacturer’s control.

The reality is that once products enter an outside warehouse, the product manufacturer still owns the consequences of how their products are stored, protected, and traced, which is why managing 3PLs, warehouses, and DCs like any other supplier is so important.

Why It Matters

Many companies treat warehousing and distribution as downstream logistics functions rather than as critical control points in the food safety supply chain system. But there are clear ramifications from doing so. Storage, handling, pest control, sanitation, segregation, temperature control, inventory rotation, and traceability can materially affect product safety and quality. A product that was manufactured safely can still become contaminated, damaged, misidentified, or rendered unsuitable for sale during storage or distribution.

Outsourcing logistics does not remove responsibility. Brand owners, manufacturers, importers, distributors, and retailers may still face recall costs, customer claims, regulatory scrutiny, reputational harm, and business interruption if a third-party facility fails. Many consumers and customers will associate a third-party facility recall with the product brand, not the warehouse or DC where the failure occurred.

Key Risks Created by Outside Warehouse and Distribution Suppliers

Outside warehouses and DCs can introduce risk in several ways. The most prevalent is exposure to unsanitary conditions from pests, standing water, damaged packaging, poor housekeeping, inadequate waste management, or commingled storage. However, the risk profile is broader than sanitation alone and can include the following:

Inadequate product traceability or lot-level visibility.
Weak recall support or slow access to records.
Inadequate temperature control and missing or incomplete temperature records.
Improper segregation of allergens, chemicals, or incompatible products.
Expired inventory, undocumented rework, or relabeling activity.
Poor contractor oversight and insufficient facility security controls.

The highest risk facilities tend to be those that handle mixed-product categories, high-inventory turnover, small-lot distribution, damaged or returned goods, and products from many unrelated manufacturers. In these environments, one sanitation failure can affect hundreds (or even thousands) of SKUs and create a complex recall that requires coordination across multiple brands, retailers, regulators, and consumers.

Material and Measurable Impacts

Like any recall event, the consequences associated with a contaminated warehouse event may be significant for the warehouse, but also for the brand owner and product manufacturer. A recall can trigger product holds, expanded traceability exercises, customer notifications, disposal costs, refund obligations, transportation expenses, legal review, insurance claims, and lost sales. It can also expose gaps in supplier approval programs, recall plans, and crisis communication procedures. If the company cannot quickly determine which lots were stored where, when, and under what conditions, the scope and potential impacts of the recall may quickly expand.

Key Controls for Reducing Recall Risk

Companies using 3PLs and outside storage and distribution suppliers need to employ active oversight; a simple, signed service agreement is not enough. The strongest programs qualify storage and distribution providers before use, define expectations in writing, verify controls onsite, monitor performance continuously, test recall readiness, escalate early, document decisions, and requalify when risk changes—just as they would any other supplier.

The following actions can help to reduce recall risks and create a robust program to maintain warehouse compliance:

Treat warehouses and 3PLs as critical suppliers. Include outside warehouses, DCs, fulfillment centers, and cross-dock operations in a formal Supplier Approval Program. Risk-rank them based on product type, storage conditions, regulatory category, geography, history, volume, and whether they handle mixed-product categories.
Conduct structured due diligence and onsite audits. Before onboarding a 3PL, evaluate regulatory status, inspection history, certifications, insurance coverage, facility conditions, sanitation and pest management records, temperature-control capabilities, recall history, subcontractor use, and ability to support lot-level traceability. Audits should verify conditions directly; desk reviews are not enough.
Require documented pest prevention and sanitation controls. Service agreements should require pest control maps, service records, trend reports, sanitation schedules, inspection logs, corrective actions, and evidence that findings are investigated and closed. Recurring pest activity, unexplained droppings, damaged doors, open dock gaps, or poor housekeeping should trigger escalation.
Strengthen traceability and lot-level visibility. Manufacturers need to know which products, lots, and dates were stored at each facility. Ensure warehouse management systems support rapid retrieval of receiving, storage, movement, shipping, hold, and destruction records. If the affected lots cannot be isolated quickly, recall scope and cost will increase.
Build recall obligations into supplier agreements. Agreements should define notification timelines, record access, product hold authority, communication responsibilities, destruction documentation, refund or recovery provisions, and cooperation with regulators. Companies should test these requirements through mock recalls involving the 3PL or warehouse supplier.
Monitor performance continuously. Regular supplier oversight should include audit performance, corrective action closure time, pest activity trends, sanitation findings, temperature deviations, damaged goods rates, inventory accuracy, customer complaints, shipping errors, product hold events, regulatory findings, and mock recall completion time. These indicators should drive supplier risk ratings, audit frequency, and escalation requirements.
Re-evaluate suppliers and maintain alternatives. Reassess 3PLs annually and when they add facilities, change ownership, expand product categories, increase volume, add subcontractors, receive regulatory findings, or experience contamination, temperature, traceability, or security incidents. Prequalifying backup suppliers can help support faster recovery if a logistics partner fails.

Key Takeaways

Warehouse and distribution controls are product safety controls. Outsourcing logistics does not outsource responsibility for product safety, traceability, or recall readiness. One sanitation failure at a multi-brand warehouse can create a complex, expensive, and highly visible recall. As such, brand owners need to manage 3PLs with the same discipline applied to manufacturers, ingredient suppliers, and other critical suppliers. The most effective programs are proactive, documented, risk-based, and supported by evidence to remove recall risk before it becomes a liability.

13 Jul

Environment / Food Safety / Information Management Solutions / Quality / Safety

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