Friend, Get the latest FDA and USDA regulatory information in our monthly EASeNews.
View in browser
EASeNews-Banner

Foods  •  Dietary Supplements  •  Drugs  •  Medical Devices  •  Cosmetics  •  Tobacco  •  Cannabis

1700 Diagonal Road, Suite 750, Alexandria, VA 22314  •  571-447-5500  •  easconsultinggroup.com/contact

March 2024

Issue of the Month

Are You Ready for the Unspoken Challenges of FSMA 204?

Featured-Image-Half-Are-You-Ready-for-204-(Alayan)

By Norman Alayan, EAS Independent Consultant

“The FDA final rule on Requirements for Additional Traceability Records for Certain Foods (Food Traceability Final Rule) establishes traceability record-keeping requirements, beyond those in existing regulations, for persons who manufacture, process, pack, or hold foods included on the Food Traceability List (FTL). The final rule is a key component of FDA’s New Era of Smarter Food Safety Blueprint and implements Section 204(d) of the FDA Food Safety Modernization Act (FSMA)” – (FDA.gov website).

 

It was said that the new requirements identified in the final rule will allow for faster identification and rapid removal of potentially contaminated food from the market, resulting in fewer foodborne illnesses and/or deaths." FSMA Rule 204 intends to create a more transparent supply chain that ensures safer food for all Americans. The rule also encourages companies in the food value chain to invest in digital traceability technology.

Read Full Article

Under the Microscope

Scrutiny on Food Traceability Lists Creates Havoc for Manufacturers

Featured-Image-Half-Scrutiny-on-Food-Traceability-Lists-Creates-Havoc-for-Manufacturers-(FSNS)

As a member of the Certified Group and Food Safety Net Services, EAS clients have access to world-renowned testing laboratories that meet your organization’s sophisticated needs. In this column, you’ll hear about their capabilities, environmental challenges and more. We hope you’ll enjoy a look “under the microscope.”

FDA’s laser focus on food traceability as part of a Smarter Era of Food Safety under the Food Safety Modernization Act (FSMA) has translated into great strides in the protection of the U.S. food supply. In January 2023, FDA strengthened these efforts with a final rule that established Additional Traceability Records for Certain Foods, produced domestically and imported, included in the Food Traceability List.

 

From farm to table, firms producing foods on the Food Traceability List must track specific Key Data Elements (KDE) for Critical Tracking Events (CTE), both forward and backward in the supply chain. This framework forms the foundation for effective and efficient tracing of food.

Read Full Article

EAS Trainings

Claims Substantiation Seminar

March 14, 2024

 

Reassessment of EMPs Webinar

March 27, 2024

 

Better Process Control School (BPCS)

April 25, 26, 29 & 30, 2024 

Upcoming Tradeshows and Conferences

FDLI Food and Dietary Supplement Safety and Regulation

Washington, DC and Virtual

April 3, 2024

Gold Sponsor

 

TMA Annual Meeting

Arlington, VA

April 22-24, 2024

Co-Sponsor

 

Petfood Forum

Kansas City, MO

April 29 – May 1, 2024

Event Presenter and Exhibitor

 

Food Safety Summit

Rosemont, IL

May 6-9, 2024

 

FDLI Annual Conference

Washington, DC and Virtual

May 15-16, 2024

Gold Sponsor

 

Next Generation Nicotine Delivery USA 2024

Miami, FL

June 19-20, 2024

 

IFT First 2024

Chicago, IL

July 14-17, 2024

Event Exhibitor

 

American Convention of Meat Processors and Suppliers
Omaha, NE
August 1-3, 2024

Event Exhibitor

FSNS

Food Safety Net Services (FSNS) Education

 

Interested in more food safety training? FSNS offers live and virtual education events. Visit FSNS.com/education to learn more.

FSPCA Preventive
Controls for Animal Food or Human Food (PCQI)

 

HACCP Training Course

 

Advanced HACCP/Preventive
Controls 

 

FSSC 22000 and/or Internal Auditing

 

Microbiology and Food Safety 101 and 202

 

Preventive Maintenance

 

Sanitation Courses

 

Implementing SQF Systems Ed 9 and Internal Auditing

 

BRCGS Food – Issue 9 Sites Training and/or Internal Auditing

 

and many more...

Drug-and-Device-Corner-Header-Square
Read the Drug and Device Corner on the EAS Website
FDA-Corner-Header-Square
What’s New on the FDA Website

FDA and USDA Regulatory Updates

FDA Issued a Final Guidance Document on CARES Act Reporting Requirements

FDA Announces Release of First Final Guidance Section for NDIN – NDI Notification Procedures and Timeframes

EAS in Action

EAS is on the go. Find out about our latest seminars, webinars, speaking engagements, articles published in industry journals, tradeshows and more!

Featured-Image-Half-2024-Petfood-Forum(Lombardo)

Tim Lombardo Presenting at 2024 Petfood Forum

EAS Senior Director for Food and Beverage Consulting Services Tim Lombardo will present Pet Food Safety and Regulatory Updates during the 2024 Petfood Forum covering pet food FSMA compliance.

Featured-Image-Half-Claims-Substantiation(Brock)

Claims Substantiation Seminar

Presented by Paula Brock, PhD., EAS Senior Regulatory Consultant
March 14, 2024

It is required in the United States that manufacturers and other advertisers of dietary supplements such as distributors, retailers, and endorsers, have adequate substantiation that the claims made about their products are “truthful and not misleading”. The Federal Trade Commission (FTC) released an update of their substantiation guideline in December 2022. Combined with the FTC guideline, the Food and Drug Administration (FDA) guidelines and regulation provide the framework for claims and claims substantiation for U.S. dietary supplements.

 

This two-hour training will be a scientific dive into the regulatory requirement of claims substantiation. Several topics including the following will be discussed along with real case examples: which types of evidence are available and where to find them; what are high quality and low quality evidence; when is the evidence irrelevant to the claim being made; and how to write claims that can be substantiated.

Register Now
Featured-Image-Half-2024-Cosmetic-Safety-Substantiation(Brock)

Cosmetic Safety Substantiation Seminar: Coming (Again!) Soon

Thank you all who joined our recent seminar on Cosmetic Safety Substantiation presented by Paula Brock, PhD, MCSI. Due to popular demand, we will schedule a repeat of the seminar this spring. Sign up to be directly notified when our new date is announced!

Featured-Image-Half-Key-takeaways-from-EAS-Cosmetic-Safety-Substantiation-Seminar(CosmeticsDesign)

Media Spotlight: Cosmetic Safety Seminar and EAS Senior Consultant Paula Brock

Missed our recent seminar on cosmetic safety substantiation? Check out these key takeaways from CosmeticsDesign.com: https://www.cosmeticsdesign.com/Article/2024/03/05/Key-takeaways-from-EAS-Cosmetic-Safety-Substantiation-seminar

Featured-Image-Half-Reassessment-of-EMPs-(Grabarek)

Webinar on Environmental Monitoring Sampling Programs

Sign up today for our complimentary webinar on Reassessment of EMPs: Have You Identified the Correct Sampling Locations to Protect Your Product? This free webinar will take place Wednesday, March 27 at 1pm ET. 

Sign Up Today!
Featured-Image-Half-Drug-OTC-GMPs-and-Labeling

Just Announced: OTC Labeling and Claims GMP Spring Course

Sign up today for our seminar starting March 27, presented by the EAS Consulting Group team.

If you manufacture products in the OTC-drug space, including homeopathic, the challenges of FDA regulatory requirements become confusing. With a mixture of regulations spanning pharmaceutical Good Manufacturing Practices (GMPs) per 21 CFR Part 110 for pharmaceuticals, and proscriptive monographs categorized by therapeutic classes, covering labeling and claims, as well as registration and listing requirements under 21 CFR 207, these nonprescription products are held to intense scrutiny.

 

EAS’s five-part series on OTC GMPs and Labeling Compliance covers what you need to know to manufacture and market your products in accordance with FDA requirements. Covering inspection enforcement, labeling requirements, private label distributors, registrations and listings of your facilities and products as well as how to design an effective Adverse Events Reporting program, our team of experts will help you to understand what is required and how to comply.

Register Now
Featured-Image-Half-Foster-a-Sense-of-Belonging(Quality-Magazine)

Media Spotlight: EAS Senior Director Lisa El-Shall

EAS Senior Director for Drug and Devices Services Lisa El-Shall recently contributed a feature article to Quality Magazine. Read Fostering a Sense of Belonging online: https://www.qualitymag.com/articles/97816-foster-a-sense-of-belonging

Featured-Image-Half-FDA-Plan-to-Ban-Hair-Relaxer(KFF-Heath-News-Bailey)

Media Spotlight: EAS Consultant John Bailey

John Bailey, an EAS consultant and the former director of FDA’s Office and Cosmetics and Colors, shared his thoughts with KFF Health News on FDA’s Plan to Ban Hair Relaxer Chemical Called Too Little, Too Late. Read more: https://kffhealthnews.org/news/article/hair-relaxers-straighteners-formaldehyde-carcinogen-fda/

Featured-Image-Half-TMA-2024(EAS-Labstat)

EAS Consulting Group and Labstat are proud sponsors of this year’s Tobacco Merchants Association Annual Meeting happening April 22-24, 2024, in Arlington, VA.

 

EAS Consulting Group and Labstat are proud sponsors of this year’s Tobacco Merchants Association Annual Meeting happening April 22-24, 2024, in Arlington, VA. Visit our booth or join a discussion with industry professionals. Registration is now open at TMA.org/2024. We’ll see you at TMA 2024!

Submit Your Questions to the EAS Team Today!

Do you have a regulatory question or concern? Are you interested in seeing a particular topic covered in a future issue of eNews? We want to hear from you! Use the EAS Contact Us form to send a note or question to our team any time.

Get Notified When Trainings Are Scheduled

Are you looking for training in a particular industry or regulatory topic? Review our list of available topics and sign up to be notified when your course of interest is scheduled next.

Featured-Image-Half-On-Demand-Webinars

We’re Hiring Independent Contractors!

EAS is always interested in broadening our industry experience and expanding our independent consultant team. If you’re interested in joining EAS as a 1099 contract employee, please email your CV to Dean Cirotta at dcirotta@easconsultinggroup.com.

Consultant Corner

EAS offers over 150 independent consultants strategically located around the globe whose expertise provide core value for clients.

Issue of the Month Author

Kevin Walls, MBA

EAS Consulting Group, Independent Consultant

Norman-Alayan

Norman Alayan has extensive experience in the fields of Quality Assurance, R&D, Production, Operations, Auditing, Consulting, and Training in Management Systems (Quality, Food Safety/HACCP, OH&S, Environment) in food manufacturing industries managing company’s QA, R&D, Production, and other areas of Operations Management. He has a proven history of success in developing, implementing, and maintaining Integrated Management System (ISO9001, HACCP, GFSI, SQF, BRC, FSMA Preventive Control, FSVP, ISO22000, FSSC22000, IFS Food and Logistics, Trace Gains, Supplier Management, OH&S and Environmental Standards, FDA, and USDA standards). Norman is an experienced manager, auditor, consultant, and trainer with practical skills obtained from work in the USA, Australia, New Zealand, Asia, and other countries. He has audited numerous global companies including Sara Lee, GE Healthcare, Kraft Heinz, Mondelez, Nestle, Con-Agra, Cargill, Anheuser Busch, ADM, Costco, Walmart, ALDI, Gate Gourmet, Newrest, Novozymes, and more.

Meet New EAS Consultants

Jeff VanderHoek

Jeff-VanderHoek

Jeff is a Medical Device RA/QA professional with over 30 years of experience in developing Quality Systems that meet or exceed FDA and ISO requirements and Regulatory Submissions. He has hosted numerous FDA and Notified Body Audits wherein no or very few nonconformances were raised/found and has prepared several successful FDA Meeting Requests and IDE submissions as well as MDD submissions and an MDR submission that recently obtained the CE mark. For over 12 years, he has worked auditing Clinical Research Organizations used for Clinical Research Studies, as well as providing updates to Clinical Investigators and the FDA on the progress of Clinical Studies.

Learn more about working with EAS

Respected  •  Experts  •  Ethical  •  with Integrity

EAS Consulting Group, 1700 Diagonal Road, Suite 750, Alexandria, VA 22314, USA, (571) 447-5500

Manage preferences