Food Safety Planning for Smaller Food Companies

Ensuring the safety of your products isn’t just a regulatory checkbox; it’s the foundation of trust, quality, and long-term success for any food business, regardless of size. A well-crafted food safety plan protects consumers, fortifies your brand reputation, and sets you up to scale with confidence.

Smaller food businesses, those averaging under $1.2 million in annual food sales, are exempt from the FDA’s Preventive Controls for Human Food rule under the Food Safety Modernization Act (FSMA). However, exemption doesn’t equate to immunity. Roughly 72,000 U.S. food manufacturers exist today; about 46,685 must follow FSMA’s preventive controls, leaving 25,315 exempt, yet still at risk without a plan.

Even if not legally required, crafting a tailored food safety plan demonstrates due diligence, satisfies many buyers’ requirements, and reduces liability.

Core Components of a Food Safety Plan

1. Hazard Identification: Map out all potential food safety hazards, physical, chemical, biological, intentional adulteration, and radiological, at each step of your process.

2. Preventive Controls

   • Process controls (e.g., temperature, time)

   • Allergen controls (e.g., segregated ingredients, labeling)

   • Sanitation controls (e.g., cleaning schedules, verification)

   • Supply-chain controls (e.g., supplier approvals, raw material testing)

   • Any other process steps, PRP, etc., that you may have, must be controlled to prevent a reasonably foreseeable hazard.

3. Critical Control Points (CCPs) Use flowcharts and decision-tree tools to pinpoint where you can apply controls to eliminate or reduce hazards to acceptable levels.

4. Good Manufacturing Practices (GMPs) & Prerequisite Programs (PRPs) Establish foundational practices; facility maintenance, employee hygiene, and equipment calibration to support preventive controls.

5. Recall Plan: Define roles, communication channels, and steps for a swift, effective product recall if needed.

6. Reanalysis Commit to periodic reviews and updates of your plan, especially after process or product changes, deviations, or emerging hazards.

Step-by-Step Guide to Building Your Plan

1. Assemble Your Team Designate a qualified individual (a trained PCQI or hire a competent consultant) responsible for plan development, verification, and reanalysis.

2. Describe Products and Processes. Create detailed flow diagrams for each product line, from raw receipt through processing, packing, storage, and distribution.

3. Conduct Hazard Analysis. For every process step, list possible hazards, their sources, and assess severity and likelihood.

4. Determine Preventive Controls & CCPs. For each significant hazard, decide whether it’s best managed by preventive control or designated as a CCP.

5. Establish Monitoring Procedures: Define how you will track control measures (e.g., temperature logs, allergen swab tests) and who is responsible.

6. Verify and validate schedule internal audits, microbial testing, and calibration checks to ensure controls work as intended.

7. Document: Keep clear, dated records of hazard analyses, monitoring data, corrective actions, training logs, and reanalysis notes. Maintain control documents defining specific requirements for required activities.

   
   

Recordkeeping and Documentation

Robust documentation provides a strong foundation for a Compliant Program. An effective documentation program aids in preventing and swiftly addressing issues should they occur. Documentation should include:

• Hazard analysis worksheets

• CCP/PC monitoring logs

• Corrective action records

• GMP/PRP verification reports

• Training certificates

• Reanalysis and update summaries

• Of course, all documentation required by your FS and Q Standard.

Training and Culture

No plan thrives without people who understand and own it. Invest in regular training sessions that:

• Explain why each control exists and the roles of your Prerequisite Programs

• Demonstrate effective monitoring and recording

• Empower employees to flag potential issues

• Reinforce a culture of food safety and quality accountability

Tools and Resources

• PCQI for Human Food criteria.

• Training protocol related to your FS and Q Standard of choice

• FDA Food Safety Plan Builder: Interactive template guiding you through each section of a compliant plan

• FSIS Guidebook for HACCP Plans: Practical examples for small and very small establishments implementing HACCP principles

• Industry associations and local extension services: Often provide free workshops or templates tailored to your region and product type

Beyond Compliance: Building Brand Value

A documented, actively managed food safety and quality program that does more than check regulatory boxes. It:

• Differentiates you in a crowded market

• Opens doors to new buyers and retailers

• Demonstrates commitment to consumer well-being

• Lays groundwork for future certifications (e.g., SQF, BRCGS, FSSC 22000, GMP)

By investing time and resources into a customized food safety and quality program, smaller companies not only reduce risk but set the stage for sustainable growth and industry leadership.

Ready to get started? Start this week by identifying a multidisciplinary Food Safety/Quality Team that can establish a value-added process flowchart related to your operation, and you’ll be on your way to a safer, stronger food business.

Don't forget to sign up for our In-Person Food Safety Workshop Courses:

SQF 10: Be Prepared Sept. 29-30

Book Now