The Food and Drug Administra-tion’s time-clock for enforcing the most important FSMA regulation, the “Preventive Controls for Human Foods (PCHF)” started in mid-September 2016. As I write this in early December, it appears that FDA will be training its field investigators and regional milk specialists well past the end of 2016. This is important as FDA leadership has committed to not beginning the FSMA PCHF enforcement process until the field staff is completely trained.
In any case, it is likely that a number of non-Grade-A dairy plants will be experiencing FDA enforcement of the PCHF requirements in 2017. The great unanswered question is whether these large plants are ready.