The FDA has just released the first two FSMA rules.
The rules go into effect on July 3, 2011.

The first rule
allows the FDA to detain food it believes has been produced under insanitary or
unsafe conditions – and not just when the FDA has evidence that the food product
was contaminated or mislabeled so as to present a risk of adverse health
consequences or death.

The second rule
requires anyone importing food into the US to advise the FDA if any other
country previously refused entry to the same product.

Both regulations
should be factored into the underwriting decisions made by product recall
insurers as both regulations expand the scope of products that will never make
it to the end consumer.

For more information about this post, or WCM’s
product recall practice, please contact Bob Cosgrove at .