Small businesses have a federal food-safety compliance date on the calendar for July 27, and as far as we can tell, nobody has moved it. Routine inspections of larger facilities were postponed this spring as travel and social-distancing rules made them impractical, but the underlying compliance deadline for smaller operations under the intentional-adulteration provisions of the federal food-safety law hasn't officially shifted. That gap between "the inspections are paused" and "the deadline is unchanged" is exactly the kind of ambiguity our smallest members have been asking us to help clarify.
Here's why it matters beyond paperwork. Whether a facility counts as a small business or a very small business under the relevant thresholds is based on average annual sales over a rolling multi-year window. A lot of our members had sales collapse in March and April and are only now climbing back, which means this year's numbers are going to look unusual in ways the original rule never anticipated. A member who was solidly mid-sized last year could plausibly fall into a smaller category this year, or vice versa, depending on how badly a given quarter got hit and how the averaging window happens to land.
What we've asked for
The Food Safety Committee has been drafting a formal request asking the federal regulator for two specific things: written clarification on how a single anomalous pandemic year should be treated in multi-year sales averaging for exemption purposes, and a public commitment on whether the small-business compliance date itself is under review given that many facilities lost weeks of normal operations to reduced staffing, supply disruptions, and, in some cases, temporary closures. Neither of these is a request to weaken the underlying food-safety requirements. It's a request for the rule to be applied to a year that doesn't look like any other year the rule was written around.
We know this affects members differently. If your facility was already solidly above the very-small-business threshold before the pandemic, this is mostly background noise for you. If you're closer to the line, or if a rough spring pushed your numbers in a direction you didn't expect, this is worth tracking closely, because your compliance obligations for the rest of this year may hinge on an answer that hasn't been given yet.
If you want to add your voice, the advocacy page on the member portal has a short template for members whose facility classification may be affected, and it takes about ten minutes to file. We've found that regulators pay more attention to actual affected businesses describing their own numbers than to a federation making the case in the abstract, so specific member input genuinely changes how much weight this request carries.
We'll update this page as soon as we hear anything concrete, and we'd rather tell you "still no answer" honestly every few weeks than let this quietly drop off the radar. If your facility is wrestling with this classification question right now and you want to talk through it before filing anything, the Food Safety Committee is taking questions through the member portal.
The International Cheese Federation (ICF) and More Cheese are entirely fictional. This post is demonstration content created for MemberJunction. All people, organizations, events, courses, certifications, figures, and quotations in it are invented, and nothing here represents a real association, a real business, a real person, or real professional advice.