 Good afternoon everyone and welcome to the CPA, the Association of Contract Packagers and Manufacturers webinar. Today we will be discussing the components of a food safety program to meet new FISMA requirements. I am Ron Puvak. I am the Managing Director of the CPA. As you can see on your screen you will see that a few slides very briefly describing the CPA. We are the voice of the Contract Packager and Manufacturer, primarily United States, Canada and Mexico. We have a very active program to assist the industry through a variety of waves, trade shows, education, networking and our ever popular RFQ tool. Part of today's session is part of our education program where we are looking to help educate the industry. We have been an associate since 1992 and we continue to strive to increase the awareness of contract packaging, contract manufacturing as well as the other aspects of our industry. All attendees are in mute right now and if you have any questions please use the question box on your screen. We will get to as many questions as we can as we get to the end of the webinar. The webinar is being recorded and will be posted on the CPA website at contractpackaging.org within a day or two. So if other colleagues want to view it you are more than welcome to come back to that site. At the end of the webinar you will see a link for a very brief survey. Please provide us your feedback. Now let's get started. Today we are pleased to have Brian Stegman, Engineering and Food Safety Manager for Ingredient presenting today's information. Brian is a long time advocate for food safety. He has worked in this area for many, many years. He also works with many of the national and federal organizations to provide guidance on new impending regulations. Brian is really considered an authority in these matters related to FSMA. So with no further ado, Brian, I would like to hand it completely over to you and please take it away. All right. Thank you, Ron. Appreciate it. So as Ron touched on, I am going to be walking through a presentation that is going to be talking to you about food safety. I wanted to start with the agenda and kind of talk through what we are going to do. Why is this topic important to you? What should you come away with? Provide some definitions to you because that is one of the things that the government likes to do is they have lots of nomenclatures that they use for various things and need to know what those mean. I want to talk specifically about the components of the Food Safety Program. What do you need to worry about as a manufacturer or a user of the products? I am going to give you a brief FSMA update on the latest things that have happened over the past year and a half. I am going to touch briefly on some customer-driven programs and then as Ron mentioned, we will have time for questions at the end. So let's get started. So why is it important to you? Food safety is everybody's responsibility. It has many facets. Maintaining a quality ingredient is critical to your infrastructure. Protecting it to make sure that there isn't any contaminants that get introduced into the product, whether it is intentional or unintentional. And the intentional, the unintentional part, the part of the intentional has been made a requirement as part of one of the FSMA requirements called intentional adulteration. But I will get on that later on in the slides. What should you come away with? Some important definitions. Hopefully you will have a much better understanding of what makes up a good food safety program. What are some of the things that have caused the program to change? How has the government addressed these issues? Specifically, how has FSMA impacted these programs? And then I also mentioned that I am going to talk about some of the customer-driven programs that have come out of these FSMA requirements. Okay, some basic definitions. Food safety. Food safety is the handling, preparation and storage of food and prevent food-borne illness from occurring. Food security, that's a WHO definition, is for having an adequate food supply. It is not the same as food defense, which food defense definition is the protection of your food system from intentional adulteration. More specifically on food defense, what that area covers, it talks about deliberate acts. And those deliberate acts are looking at ways of causing harm to you and your products. And what the program does is it's ways of how do you reduce that exposure, how to reduce the risk of those incidents happening, reduces your overall business disruption. It guarantees a good, safe and wholesome food. And by doing that, you reduce the risk of losing your customer loyalty because they know that you're doing your job to make sure it's working and they don't have to worry that the product that they're getting may be at risk. And as kind of a hidden note, it ensures job security for your employees. So here's what the components of a food safety plan to meet current good manufacturing practices under FDA. You have to perform, you have to have a hazard analysis, you have to have preventive controls, you've got to be doing monitoring, corrective action, verification, record keeping and you need a food defense plan. And I'm going to go into each one of these individually. Hazard analysis or as harp, you identify where your hazards are. You evaluate those hazards and then you want to make sure that you know or reasonably know what foreseeable hazards that could be occurring in food manufacturing part of the process, whether it's in that portion or whether you're processing food or if you're just holding the food or if you're just packing it out after a finished ingredient. So that's part of your hazard analysis. Preventive controls. Now these preventive controls, and I've touched on a few of them, but they reach into areas, they talk about the processes, controls making sure your process is staying in control. If you have any food allergens, making sure you have good controls to control those food allergens so they don't provide go across your process. Make sure you have good sanitation controls and you need to make sure you've got an excellent recall plan. So if there is an incident where you do have a problem, you have a very robust program that you're able to recall the product. Monitoring. And this is one of the things that within FISMA that they've kind of made sure that they reached out to. You need to make sure that you're not only looking internally into your system, but also looking at your suppliers, the people that are bringing your products in, your raw materials that are coming into the process. Make sure that you have an internal program, but they also have an audit program to make sure they're doing things correctly, and that you have a process that can go out and audit those programs. And you want to make sure that it's not just the manufacturing that's making the ingredient, but also where those products may be held, like in a warehouse. If you're going through a break or transfer station, or if you've got like a liquid ingredient and you're having to bring in and have a trailer loaded with it, making sure that that wash station meets those same requirements. Corrective action. This is really key to your food safety plan because you want to make sure that you not only correct the problem, but you also want to make sure you're minimizing the likelihood of that reoccurrence. Things do happen. You can't have an issue. You can't have issues in your process. The key to the process is in making sure that once you identify the problem, you correct it. You make sure that if there is an issue, you prevent that product from entering into the commerce or into our food supply. And the other thing that's critical to this is you need to make sure that you continually look at your food safety plan, because as you know, things change as you're going along in the program. And you need to make sure that the food safety plan that you established originally is still meeting all the requirements and all the equipment and all the processes that you've put in place. And if you've made any changes or expanded your lines, making sure that those programs have been updated to be in place for these programs and make sure that your food safety plan reflects that. Verification. Verification is a critical piece of your preventive controls because you've got to make sure that when you're doing your testing, you've got to have a means to verify that the activities that you do, for your preventive controls, have been validated against some standard. So for example, if you're using a temperature probe for measuring the temperature of an ingredient, you need a process in there that goes in and checks the calibration on that temperature probe to make sure that it's within those standards. And if not, you need to make sure that you've got a process for adjusting it or if in some cases replacing that device to make sure that the instruments that you're using are acting as operating as planned and within specifications. That program, the verification program, you need to make sure that you, when you're doing that, that you're recording the records of that information. And that is part of when you're going through your food safety plan, making sure that this verification program has addressed those issues. If you've had some preventive controls that have changed, you've gone into the process and readjusted those. The other thing that's critical to the verification process is you make sure that it's not only the product itself that you're testing, but also the environment that you may be. For example, if, for example, you're using incoming water into your process, making sure you've got a good third party that's going in and testing the water and not just relying on the city say you're using city water, not just using the testing results from that city because you really need to be looking at the point of use of the product that you're using. If, for example, you're water that you've got, making sure that that water does meet sanitary standards and is potable. The other part of it that sometimes people miss is you need to make sure that when customers are complaining about something that has happened within their delivery, you need to look at that customer complaint to make sure that you get to the root cause of exactly why that customer is complaining so that you're addressing it so you're not going back and having that same issue over and over again. Record keeping. Record keeping is critical to FISMA, FDA as they have come back and said that you need to make sure that you've got adequate and accurate record keeping. And that record keeping includes making sure you've got a written food safety plan with that hazard analysis. You need to make sure that you have records on what you're doing for your provide of controls, how you're monitoring the process, any corrective actions that you've made to that, to any changes to the process, and the verification that you've tested and the equipment is acting as designed and providing exactly what you're looking for. Now let's talk about the food defense plan. Now the key to the food defense plan, it needs to have these following pieces. They need to have actionable process steps. They need to, when you create the plan, you need to have focused mitigation strategies that look at where your risks are. And then as you can see, the monitoring corrective action and verification, just like the food safety plan, those programs need to be in place with your food defense plan. In addition to that, you need to make sure that your employees are trained in that food defense plan. And as always, making sure you have got good record keeping so that if there is an incident and you do have a problem and FDA comes in and they want to look to see exactly what goes on, you're able to provide them the support that shows that you're meeting their requirements. Now let's talk briefly about the government agencies. So depending on the type of food industry you're in, you may be reached into by the FDA, USDA, DHS, and CBP if you are using products and you have food defense plans, they're part of the program that potentially can come in. Now within FDA, you've got FISMA. So what they're looking for, and this was all part of the, when they came out with the FISMA requirements originally, they wanted to make sure that you had preventive controls for human food. You made sure that if you're bringing in products outside the U.S., you have a foreign supplier verification program. The Sanitary Transportation Act was something that came out originally that had been updated last year. The IA rule talks specifically about intentional adulteration and what FDA is doing as far as how they're implementing this rule as it has come out. And then some of the other pieces is we'll talk about customer-driven programs, things like ISO 22000 or BRQ or SQF type programs that are out there. So let's just talk a little bit more about the government agencies. So how have these companies, how have these agencies changed their lives? And how, what are the things that they've done? So DHS, ever since 9-11, has become an integral piece of the information. And as part of the critical infrastructure program that has been established, our food supply and our water and those ingredients are critical to making sure that those products don't get adulterated by either foreign bodies or even people within our own society. Customs and Border Protection, because of the new requirements with regard to Homeland Security, they have stepped in and doing that. And then as I talk about FDA, it's the frisma requirements. Homeland Security. I thought I'd share this little slide. It's been around fighting terrorism since 1492. Homeland Security has been something that's been critical to our business and our livelihood. And the only thing that's really changed is the methodology of how we're doing it. So let me just talk briefly about how Homeland Security is made up of. It's made up of these various organizations, CBP, the U.S. Coast Guard, TSA, Secret Service. And then the FDA and USDA has an interface with this group. And so there's an acting body that monitors that group, and I'll touch on that a little bit further. So what's changed? Well, if you travel and you go through the airport, the days of showing at the airport 15 minutes before your flight are long gone. Now going across the border, even going across from the U.S. into Canada or in from the U.S. into Mexico has changed dramatically. The other things that have changed is when products are being brought into the U.S. through our ports. Those products now are being scrutinized on a regular basis with some very elaborate equipment. And our day-to-day business, the way we do business is much different today than it was. What does CBP, what's their role? Their role is they're in charge of inspection of border crossings, inspection of illegal aliens. They're also responsible for threat mitigation. Now one of the roles that CBP has done a lot with is providing training for our industry, our food industry in support. So as people are trying to learn about what they need to do and what kind of programs they need to have, they have been very strong in providing that forefront in the training for those programs. Here's just some general information. On a typical day, as you can see, 493 terrorism inquiries, 3257 apprehensions for illegal entry. I'm sure that number is much larger of late. And over 968 citizens are a refused entry. One of the things that people don't realize is that there's a huge amount of stuff that goes on at the border, at the ports. And so one of the things that they've been able to do is step in and trying to figure out what's going on. As you can see, one in 27 employees are caught stealing from their employers. So let's talk about FSMA. FSMA, it was a food safety law passed by Congress in 2010. The goal is to provide a good food safe source. I touched on these. These are the main components of the FSMA requirements. Now let's go into a little more specifics. So preventive controls. Preventive controls, making sure that your facilities, you want to make sure that your food safety plan and your food defense plan include the following. Hazard analysis. Making sure you've got preventive controls. Oversight and management controls, and these are similar to your regular food safety plan, but making sure you've got a monitoring, corrective action, and also verification in those programs. You also want to make sure that your preventive controls reach in not only into your manufacturing and process, but you need to make sure that you're also looking at your raw materials. So you want to make sure that you're using approved suppliers, people that you know that you do business with, and that if you end up bringing in a new supplier, you've got a program in place to go in and actually verify their activities and what they say they're doing they're actually doing. I talked about good manufacturing practice. We need to make sure that all employees are qualified to perform their job, and those employees are trained in food hygiene and also in food safety. Let's touch on the foreign supplier verification program. Part of this program includes, as you can see, hazard analysis. We want to make sure that we're identifying any potential hazards in the food. We want to know that where these hazards could be when we're doing the hazard analysis, making sure that we're reaching into each of the areas so we understand exactly any person or any company that's touching the product that they have done those analysis to make sure that they're keeping our food safe. We want to make sure that they're trained in food safety programs to meet our food safety standards. The other thing that FISMA requires is you want to make sure that you're doing annual onsite visiting of those foreign suppliers that are bringing the ingredients in on all your high-risk products and then making sure that if you're bringing something in and you're not bringing it on a regular basis, you do that based on the risk of the product that you're bringing in and what is the risk of the product that's coming in could be presenting to your process. So the quality of the product that's coming in and where that product, is there a risk with the product that you're bringing into it? Here's some simple questions when you're dealing with these foreign suppliers, making sure that you've asked these questions. And this is questions for your procurement people. If they're going out and looking at that, can you identify all your suppliers? Do you know that if your suppliers, if they are also using raw materials, are they able to reach out and verify who those their ingredients suppliers are and do they meet the requirements for a good food safety plan and making sure that you define under the foreign supplier verification program who is responsible for that incoming product. Now the other piece that you need to make sure of is that you need to make sure that you've got good documentation so that if for some reason procurement is unable to get a supply, if they suddenly change that supply source, you have other suppliers that are in your process that have already gone through this program or you're not holding up your process or we're still off bringing in product that hasn't been verified that they're meeting the requirements. So some other questions you need to ask. Once you've done your risk assessment, you need to know which of those require your on-site audits. Now one of the questions that FDA and FISMA had asked is how do you know the person that is auditing your supplier is qualified? So you need to make sure that whoever is doing that, if you're using an outside third party, what are their credentials and have they been properly trained to make sure that they are qualified to verify your program so that you can rely that if they tell you that they've audited the process, everything is good, are they doing that? Now by now everybody should be aware of FISMA. So the question about asking your suppliers if they're ready for it, the answer should be yes. So let me touch on the sanitary transportation rule. This is something that's near and dear to my heart. The reason being is I had a lot of interface with FDA when they were rewriting the new rule and one of the components, one of the things that I did was to make sure that we had our input into the process to make sure that they were meeting the requirements. So the new rule, it was adopted in 2016. One of the biggest things, and I'll go into the detail on this, but one of the biggest things that the FDA, both the FDA and the USDA had come back with is they wanted to make sure that when this rule was implemented that there were programs in place that were making sure that everything that has product is being used. If you're using some sort of transport vessel to bring product in, that there is programs and processes and training in place and people responsible for the program to make sure they're in the system. So as they go through this, you'll see some of these components. So who's covered under this? Shippers, receivers, loaders. If you're transporting product either by truck or by rail. Now, with regard to the rail, the rail companies themselves have been able to be excluded from this process. But what the FDA has said, if you are using the rail and you are shipping product on the rail, you're on the hook for it. So one of the things out of this requirement is that there, the shippers are the key group responsible to make sure that any vessel that's being used for moving product is safe and sanitary. Now, one of the things that changed with the new rule was that the motor carriers now have been drawn into that process and they themselves as the carrier are now also responsible to make sure that their equipment is sanitary. One of the important pieces of it is that the person that is physically doing the loading of the product, they are the critical cog in the wheel to make sure that when that vehicle comes in, they're doing the inspection of that equipment and making sure that it's an appropriate sanitary condition. And the key piece of that is they are the person that's responsible that if they feel that that product or that vehicle is not sanitary, they're the ones that can reject it and are required to reject it. Now, the sanitary transportation requirement has broken their key requirements into two areas, animal feed and human food and then raw versus finished product. The other component to this is that there also, if you are bringing product in by rail or truck from Mexico or Canada, you're covering under this rule and also any product that you're bringing in from outside the U.S., if it is being brought in and being consumed in the U.S., then it is covered under that sanitary transport requirement. Now, the exception to that is if for some reason your product is being brought through the U.S. and it's moving on to other countries, then it's not covered under that requirement. Here's the key part to the shipper's responsibility. They're responsible to make sure that there is a written procedure to make sure that their equipment and vehicles, so if they're using transfer equipment to load that vehicle from a rail car to a truck, for example, they need to make sure that equipment is in appropriate sanitary condition. They also need to make sure that in their procedures that any previous cargo, they need to have prior load listings on their prior cargo listings so that if something comes in and the prior load information shows that it is not a food material, that is a reason for a rejection and that product should not be coming in. If the product needs to be controlled for temperature, those procedures need to be reinvented that because if the risk is that if the product, for some reason, either it gets too warm or it gets too cold and that then causes the product to be unsafe, those procedures need to be written into that. And as I said before, the person responsible for these duties are also responsible that if, for some reason, the product does not meet their requirements, that they are required to make sure that that is product held and prevent it from going into the public. So with this slide here, I wanted to just kind of talk about FISMA food defense and sanitary transport. It reaches across the whole broad process of your manufacturing. So the manufacturing making the product, receiving the product, you're putting it into warehouse and if you're shipping it down the road, all of those are tied together as part of the Sanitary Transportation Act. The other component is food defense. FDA made this statement. It's the last line of defense for a product. So one of the things that the FDA has created is they actually created a FDA tool for food defense mitigation. So it's a website that's there that you can go on to it. You can download that program and then it will help you create your food defense plan. Let me just touch on IA or intentional adulteration. This rule was adopted last year and it covers both domestic and foreign products that are registered. So if you have a registered food-grade facility under section 415 in the Food and Drug and Cosmetic Act, you are required to make sure that you are meeting the intentional adulteration ruling. And as with the other requirements, it deals with manufacturing, processing, packing and holding food. And as the overall part of food safety, the key here is making sure that the intentional adulteration has to prevent large-scale harm. So you're really trying to make sure that you can prevent any product that possibly has been adulterated from getting into the food supply. Here's just a couple of examples of intentional adulteration. Discontinental employees, competitors. They could be just looking at trying to harm the reputation of the company. But they could be doing things like economically motivated where their goal is by substituting a product that may not be a food-grade product into a process it could create some issues in the product going forward. So let's touch briefly on some customer-driven programs. So one of the things that our company deals with is FSC 22,000. The other part that we deal with is making sure that we meet the GFSI requirements, Global Food Safety Initiative. And one of the things that these programs that our customers have reached out to us to make sure that we as suppliers to them are doing is we have to be not only go out and make sure we're auditing our manufacturing facilities, but also any transfer or wash facility or any wear-offing facility. The other thing that's kind of reached out and this is an area that's close and dear to my heart is making sure that we're looking at things like flexibags, which are a bag-in-the-box type liquid bags for moving products. They typically move in drybox containers and up until probably five or six years ago product was being moved into it but there wasn't a real close scrutiny on what was the prior product in that container. And so now there's much more robust programs that are in place to make sure that if you're going to be using a container to haul flexibag or if you're hauling dry goods what is the program or process that you have in place in your system to make sure that if they're bringing a container in and you're going to put your ingredients and finish products into it how are you inspecting those to make sure that those trailers have not held hazardous chemicals off odor materials. You know, for example, and I run into this where they haul tires in the trailer. Once you see that, you'd be, wouldn't be able to put anything in. So that's my last slide. The next one I've got is is really thanking everyone for their time and then I'm opening it up to the questions for everybody. Well, thank you everybody. Appreciate you, Brian. That was awesome, awesome presentation there and just a personal note. I've known Brian for many, many years and if there is a expert in this area it is definitely Brian. We go to him quite a bit in another association. Appreciate it, Brian. We do have some questions coming and hang on a second here. Let me get them. First of all, when you're putting together a program can you give a sense of an idea of manpower, timing to put a program together? What can people expect from that perspective? Well, one of the key components when you're putting your food safety programs together, what you want to make sure that you have is you have a very robust team. So you don't want to just have your quality people putting together the food safety program while they're critical to understanding the process. You also want to make sure that you've got your operators in the program because if they're going to provide you insight into where the gaps are in the process or no, this is the program or this is the process that we have but that's not how we do it. So you need to make sure that you involve your whole team looking at not only your operators but your maintenance people. When they're doing maintenance on the equipment making sure that team member is one of your maintenance personnel. You've got your operators, you've got your quality assurance people. If you've got people that are security programs you want to bring that person into it. The other thing is also making sure that you've got your procurement and your other supply chain people in the process because there may be components or there may be things that they're doing so they understand what your requirements are when you're following the program. The key component to that is you're following the requirements under the FDA requirement under 21 CFR. So you follow that safety plan. One of the things that FDA has got there is there's a lot of reference information in there that comes with the program that are in place that you can follow and the key to it is making sure that it's consistent and that anything of your program is that it's constantly being checked to make sure that you're using the same. So you create a central database, you have the programs in place and then as you get any changes that you do the information gets updated automatically and so that everybody is always dealing with the same piece of paper. Okay, excellent. You didn't mention it but I believe the question is does packaging fall under FSMA, the packaging components fall under FSMA? If you have direct contract, if your packaging material has direct contact to the finished good, it falls under FSMA under the requirements you need to be registered. So you need to make sure that your food safety plan is, now for example one of the things for the food safety plan for your packaging goods is how are you storing that material? What are you doing to make sure that you're protecting it so that if it's being stored in a warehouse, how do you protect it from not having dust or dirt coming in contact with the packaging material as it gets ready to be placed on it? So that's why the program needs to reach into if you're doing direct food contact you need to make sure that that packaging material is meeting the requirement. Okay, now FSMA was rolled out so to speak and implemented. Are there other dates that FSMA has changes or updates in that everybody must comply? Well the latest requirements as of actually as of July 1st this year FDA is supposed to be implementing a program regarding the intentional adulteration rule and actually physically going out to sites and doing audits of facilities to make sure that they're meeting the IA requirement. All the other rules are in place and whether you're a small company or a large company all of those dates have passed and so everybody needs to be in compliance. If you have questions specifically to the physical dates if you go to the FDA FSMA website it'll actually have the dates when the laws were in place but as of the end of last year everybody was required to have programs in place. Okay, you touched on audits right there. How frequent are the audits have you seen the audits become? And penalties, compliance, time to reach compliance can you give us some handle on that? So when the IA rule came out last year one of the things that we did sit down our group I belong to is an organization that's composed of many manufacturing companies and we have a group that's part of a security group called ASIS and we actually sat down with the FDA and we talked to them specifically about compliance and how they're going to go about the program and what they came to us with is they said we want to work with you to make sure that the programs first are can be managed by various companies so one of the concerns that we had was that some of the rules that were coming out especially on the IA rule were going to be so restrictive and so difficult that many companies would not have the resource to be able to support the program. So what we did is we worked with the FDA and the group to talk specifically about those programs and so that's when I talked about actionable steps those are the components that they're looking to do. Now what they have said is that starting last year they were starting this dialogue they're completing that dialogue we're in the middle of a review right at this time with FDA we're expecting that they're going to start going out starting next year and doing audits of the program. The initial comment that they made to us was that the initial audits are not going to be where they're going to be beating you up or they're going to be pointing things out. Now what they did say to us is that if they came to a facility that did not have a food defense plan then you're going to get slapped but if for some reason in their review of your food defense plan if there were components they were missing from it they would give you time to meet those requirements without any repercussions but if you're not if you don't have the program at all you're going to get slapped with a fine. Now in the reporting part of this I mean you're putting together a food defense plan is there a reporting mechanism where you have to say to somebody I do have a food defense plan or is it purely whenever the audit comes? You need to have a food defense plan when they're going to come to you one of the first questions they're going to ask you is you have a food defense plan. Then they're going to want to review their food defense plan. So there's no formal saying you have to have one reported on an annual basis that was the question. Part of your registration as part of being registered under FISMA if you are a registered supplier of an ingredient and you're packing or holding material as part of that you are under FISMA requirements so all the rules that FISMA has implemented you are under those requirements so the expectation is that you have those programs in place. Here's an interesting one. Now this is not we're talking recalled products we're talking returned products. There's a lot of reverse logistics products going on in the marketplace these days. Good product being returned is there any FISMA requirements on those kind of products or is that so new it hasn't been touched yet? I think the way it's covered under FISMA is that are you able to control the return product coming into your process? We as an ingredient supplier run into that on occasion we'll have a customer that may not take all the products say they're getting a liquid product and they're supposed to get 4,000 gallons and they only take 3,500 gallons. That product coming back into our process the question is have you been able to control that program, that product? If you cannot verify and document that you've been in control over it the risk is that the product could have an issue and the concern is what are you doing with that product? If you bring it back into your system are you then introducing it into your supply chain? If you have a process that you're able to verify that the material hasn't been tampered with and you document that then I'd say you're fine. But if for some reason you're unable to verify that process then you're at risk. If you go through the US don't fall under these guidelines but everything coming to the United States has to be going through customs and approved. Is there a time frame that the product has to be passed through the United States that it doesn't fall under FSMA or can you give us more guidance on pass through products? The pass through products would be specifically that the product is part of a larger shipment and that product shipment that part of it is coming into the US and then it's going into a warehouse where it's then broken out and then it is leaving then repackaged and being sent out to other locations. As long as the product is not being consumed in the US it does not fall under FSMA. But if the product is coming in and it is being consumed then it falls under it. So there's a lot of bonded warehouses for example the product will come in it goes into the warehouse and then it may go out and go through some other area. Those would not fall under FSMA. That's interesting. There's a lot of energy packaging a lot. Are products and ingredients imported from NAFTA countries under the same restrictions? Is there any easing of the restrictions because they come from Mexico or Canada? No, they're under the same guidance and the same guidelines and actually the expectation is that they should be meeting every one of those requirements. Excellent. Some really good questions here. Again, I want to thank everybody for being on the webinar today. Hope you found it informative. I know I did. Brian, thank you very much for taking the time to present this to us. Again, as I mentioned before, the webinar has been recorded and we will have it on our website at contractpackaging.org within a couple of days. We have other folks in your organizations that would like to view it. We'd be happy to have you come to our website and view us and go to our website anyhow and see what contract packaging is all about, contract packaging and manufacturing. Again, thank you all. We appreciate it for your time today. Good day.