FSMA covers the operation of a facility that manufactures, processes, packs, or holds animal food for sale in the United States. It gives the FDA expansive authority over the entire supply chain of animal feed and feed ingredients, including your biodiesel plant’s production of glycerin. Not knowing which quantities of glycerin will or won’t be sold into the feed market would suggest you want to have controls in place for all quantities of glycerin.
The key to minimizing the cost and burden of the transition is proactive planning and management.
Becoming “FSMA-ready” and “FSMA-compliant” is no small undertaking. Becoming compliant, and proving your existing commitment to produce safe and nutritious animal feed products to the Food and Drug Administration (FDA), means getting acquainted with another agency of government oversight and its brand of formal food safety.
These regulatory changes can have a significant impact on the market. When you couple the limited value of glycerin as a co-product and its excess supply in the market you may even re-assess your options.
How much money are you recovering from selling glycerin (additional revenue and avoided disposal costs), and what would it cost you to become FSMA-ready and remain FSMA-compliant? Answering this question is helpful for identifying your strategy moving forward toward the FDA’s compliance deadlines.
If you’re wondering what your options for FSMA compliance are, it pays to work with a leader who understands your industry. Christianson and Associates can help you assess your readiness and determine the amount of assistance you will need to become compliant, prior to the statutory deadlines.
Our FSMA-Readiness Program and compliance team can provide you with training, resources, and technical assistance to make the transition to the FDA’s brand of formal food safety. We have an FSPCA PCQI Lead Instructor on staff and have knowledge that can help you navigate the FDA's requirements, assess your readiness, and determine the amount of assistance you will need to become compliant prior to the statutory deadlines.
Business Assistance Team
Our business assistance team can help you assess the value propositions of different strategies to managing FSMA implementation. We can also help you evaluate potential options for avoiding a compliance obligation. If so, our team of grant writers with REAP and VAPG specific experience can help you secure funds for certain types of capital upgrades. How do you assess costs and benefits of various feed market avoidance strategies?
- Can you designate your glycerin for industrial use only/not for use in food or feed to avoid oversight by the FDA? If so, what’s your disposal cost when you encounter a situation where you can’t sell your full quantity at a competitive price when limiting yourself to a smaller market segment?
- Is it feasible to upgrade your ability to further refine your glycerin to a higher quality, non-waste stream for pharmaceutical use? Depending on the ownership structure of your plant, you want help applying for a value added producer grant covering up to 50% of the costs of making necessary capital modifications to complete the project
- What would it cost to retrofit your plant to burn/incinerate the glycerin for process energy/boiler heat? A USDA REAP Energy Replacement Grant would potentially cover up to 25% of the cost of doing so.