• Posts Tagged ‘FSMA’

    Publication – Selection of Strategic Authentication and Tracing Programs

    by John Spink • February 13, 2015 • Blog • 0 Comments

    Authentication is a key to Food Fraud prevention and a critical part of the “detect-deter-prevent” continuum. Selecting authentication countermeasures that contribute to prevention is often complex and challenging. This challenge was the subject of my chapter on “The Selection of Strategic Authentication and Tracing Programs ” in the book Counterfeit Medicines : Volume I. Policy, Economics,...

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    Final “Preventative Controls” Rulemaking-Related Questions for Economically Motivated Adulteration Questions – MSU FFI Public Submission for the “Request for Comments”

    by John Spink • December 26, 2014 • Blog • 0 Comments

      How and where should FDA address Economically Motivated Adulteration (EMA) or Food Fraud? Regardless of the US Congressional Research Service (CRS) and US Governmental Accountability Office (GAO) recommendations, is there an underlying question of whether FDA has to address Food Fraud/EMA at all? Since there are many global Food Fraud activities it is...

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    Review of EMA Aspects of New FDA FSMA Preventative Controls Rule

    by John Spink • September 19, 2014 • Blog • 0 Comments

    Would the horsemeat incident be an EMA violation? Would it be regulated by FDA? TBD. Earlier today FDA released their updated Proposed Rule on “Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventive Controls for Human Food” – this includes their direction on Economically Motivated Adulteration (EMA). EMA is a subcategory of Food...

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    If ‘Disgruntled Employee’ Actions Are ‘Economically Motivated’ Is It Food Fraud and Does It Meet the FDA’s Definition of ‘Economically Motivated Adulteration”? No and No.

    by John Spink • August 11, 2014 • Blog • 0 Comments

    Does it matter? Aren’t they all just words? Not if there is a regulatory compliance issue. The US Food Safety Modernization Act (FSMA) is still determining where and how they will address ‘Economically Motivated Adulteration’ (EMA) – and there are questions beyond just the text from the Federal Register or from FSMA (see previous...

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