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CHICAGO, Nov. 9, 2016 – The Food Safety Modernization Act (FSMA) includes new rules that place food safety responsibility well beyond food manufacturers – compliance now impacts many facilities previously unaffected, according to a special report released today by Cushman & Wakefield. The report, “Food Manufacturing, Food Safety & Regulation,” examines the approved FDA rules for implementing FSMA regulations and offers food facilities some guidelines for using commercial real estate industry strategies to help comply with these sweeping changes.

“The Food Safety Modernization Act is the largest expansion and overhaul of our nation’s food safety practices in nearly 80 years,” said Jason Tolliver, Cushman & Wakefield’s head of industrial research, Americas. “This new preventative approach will affect many aspects of food control – from transporting food to the design of commercial facilities that process it – all of which will mean substantial change for food manufacturers, both here and abroad.”

FSMA fundamentally shifts the focus of food safety for the Food & Beverage industry from reacting to limit the impact of adulterated food after it reaches the marketplace, to preventing contaminated food products from reaching consumers in the first place. It gives comprehensive new regulatory and enforcement powers to the Food and Drug Administration (FDA) and affects nearly every link in the food supply chain.

The Cushman & Wakefield report examines seven rules for the Food & Beverage industry that the FDA has proposed in order to implement FSMA: Preventive Controls for Human Food; Preventive Controls for Animal Food; Produce Safety; Foreign Supplier Verification; Third-Party Certification; Sanitary Transportation; and Intentional Adulteration.

The report also provides guidelines to help aid food facilities in using their commercial real estate strategies to meet the new FSMA requirements. Among the recommendations are:

  • Start with the property: Ensuring that site elements such as security, vehicle management, site lighting, and grading and water-management systems are designed with an eye toward food safety is important for both the preventive controls and intentional adulteration elements of FSMA.
  • Establish distinct hygienic zones: Maintaining strict physical separations that reduce the likelihood of contamination from one area of the plant, or from one process, to another area of the plant or process, has become an industry standard.
  • Control the flow of personnel and materials: Establishing and following traffic and process flows that control the movement of production workers, sanitation and maintenance personnel, products, ingredients and packaging material reduces food safety risks.
  • Control water accumulation inside the facility: Water is an essential part of the food manufacturing process and one of the greatest threats to food safety. Designing and constructing floors, walls, ceilings and supporting infrastructure that prevent the accumulation of water is critical.
  • Control temperature and humidity: Ensuring that HVAC and refrigeration systems maintain specific room temperatures and control air dew point to prevent condensation helps to control microbial growth. Systems that include a purge cycle to manage fog during and dry the room after sanitation reduce the likelihood of food borne pathogens.
  • Control air quality and flow: Designing and installing HVAC and refrigeration systems that adequately filter air to control contaminants, provide outdoor makeup air to maintain specified airflow, minimize condensation on exposed surfaces, and capture high concentrations of heat, moisture and particulates at their source.
  • Use building envelopes: Designing and constructing all openings in the building envelope (doors, fans, louvers, and utility penetrations) to ensure that foreign bodies and vapor do not have access promotes food safety and efficient operations.
  • Ensure building components and construction is appropriate: Food safety can be affected by floor surfaces, wall finishes and coatings, and design items such as walk-on ceilings. Consider finishes such as impervious, resinous floors and concrete masonry walls with a block sealer and an easily cleaned high performance coating or insulated metal panel installed in a vertical orientation.

It is imperative that manufacturers understand the requirements of this new law and integrate them into the design and operation of food processing facilities. “Incorporating these food safety measures is likely to require additional costs and affect project management scheduling,” noted Tolliver. “In the long run, however, the up-front cost to ensure FSMA compliance will be less expensive than non-compliance.”

The full Cushman & Wakefield report is available at:

About Cushman & Wakefield

Cushman & Wakefield is a leading global real estate services firm that helps clients transform the way people work, shop, and live. Our 43,000 employees in more than 60 countries help investors and occupiers optimize the value of their real estate by combining our global perspective and deep local knowledge with an impressive platform of real estate solutions. Cushman & Wakefield is among the largest commercial real estate services firms with revenue of $5 billion across core services of agency leasing, asset services, capital markets, facility services (C&W Services), global occupier services, investment & asset management (DTZ Investors), project & development services, tenant representation, and valuation & advisory. To learn more, visit or follow @CushWake on Twitter.



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