The More Things Change, the More They Stay the Same with the FSMA.

Deadlines come and deadlines go and yet the new FSMA regulations (notwithstanding court orders) fail to materialize. Now, as the result of a new consent order — 2014-2-20-dkt-82-1–joint–consent-decree_26503 — (arising out of the prior litigation), new deadlines have been set. The new deadlines are:

a. Preventive Controls for Human Food (FSMA Section 103(a) and 103(c))
Final rule: August 30, 2015
b. Preventive Controls for Animal Food (FSMA Section 103(a) and 103(c))
Final rule: August 30, 2015
c. Foreign Supplier Verification Program (FSMA Section 301(a))
Final rule: October 31, 2015
d. Produce Safety Standards (FSMA Section 105(a))
Final rule: October 31, 2015
e. Accreditation of Third Party Auditors (FSMA Section 307)
Final rule: October 31, 2015
f. Sanitary Transport of Food and Feed (FSMA Section 111)
Final rule: March 31, 2016
g. Intentional Contamination (FSMA Section 106(b))
Final rule: May 31, 2016

We’ll have to see if these deadlines actually stick, but the bottom line is that, even if they do, there’s still a long way to go until the 2011 Congressional intent is realized. And, of course, there’s still that nagging issue of funding…

For more information about this post, please contact Bob Cosgrove at rcosgrove@wcmlaw.com.