This fall brings the first major compliance deadlines for rules promulgated under the Food Safety Modernization Act (FSMA), the most sweeping reform of U.S. food safety laws in over 70 years. Enacted in 2011 and now set to be implemented through seven major substantive rules-all issued within a 9-month period ending in May 2016-FSMA introduces a new era in food safety by focusing on preventing food safety risks rather than on responding to crises after they happen. As we enter the enforcement stage for the new rules, we consider the practical challenges of each rule and identify areas where enforcement may provide clarity, including in relation to one of the most difficult aspects of the final rules: regulation of the supply chain.
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