As executives in the food and beverage industry say they are preparing for the Food Safety Modernization Act, Joe Levitt, a partner in the law firm of Hogan and Lovells and former director of the FDA's Center for Food Safety and Applied Nutrition, recommends starting with the basics. "You need to be sure you have all of your food processing steps thoroughly under your control," he said, adding that record-keeping will likely be "the single biggest change most food companies face."

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