Rutherford, NJ, August 05, 2017 --(PR.com
)-- The arrival of the Food Safety Modernization Act’s (FSMA) first Foreign Supplier Verification Program (FSVP) compliance date on May 30, has created questions over the FDA’s position with regards to some of the common practices undertaken by US importers in safeguarding food imported from foreign suppliers. The FDA has adopted an approach of ‘educate to regulate’, but non-compliance is a serious issue and must be addressed by all importers.
SGS has been emphasizing the key message that compliance to FSVP requires serious effort, and in some cases a shift in the way importers conduct their business. FSVP is a pragmatic rule that addresses food safety from the importer’s viewpoint. The main requirements focus on having an effective risk management process in addition to supplier evaluation/re-evaluation, verification and approval processes. Qualified individuals should perform certain tasks, and records must be maintained for corrective actions and other activities.
Food importers need to consider the risks that result from our modern supply chains. The complexity of today’s supply chains, mean importers need to consider multiple factors in determining the risk level associated with a specific food they’re importing into the country. Factors may include:
1) The inherent food safety hazards associated with the food (known or reasonably foreseeable): Biological, chemical, physical. Also, recall history associated with the food item, history of breakouts associated with the food category, etc.
2) The depth of the supply chain of the specific product – number of suppliers involved, complexity of the supply chain, supplier manufacturing details, supplier history, supplier compliance with local and international regulations and standards
3) Risk associated with processes involved in producing, packaging, transporting and storage of the food
4) Macro factors – including the political situation in supplier’s country, regional incidents such as radioactive incidents or natural disasters, also the way rule of law is applied in the supplier’s country, local food culture, etc.
SGS, in its dealings with importers and via a series of webinars, has underlined the fact that a ‘one-size’ approach to FSVP compliance cannot work. Importers may decide that several verification activities are appropriate to ensure a hazard is being properly controlled. Whatever verification activity(ies) an importer chooses, however, SGS is advising all stakeholders to document their justification for its suitability.
Types of verification activity include:
1) Onsite audit – which is also a default verification activity when a hazard in a raw material or other ingredient will be controlled by the supplier, and is one for which there is a reasonable probability that exposure to the hazard will result in serious adverse health consequences
2) Sampling and testing of food
3) Review of the supplier’s relevant food safety records
4) Other appropriate supplier verification activities (such as inspections)
Determining risk in relation to food imports will prove even more difficult when the importer is dealing with a supply chain passing through multiple geographies and regulatory requirements. In addition, importers also need to track the regulatory data related to specific ingredients.
To achieve this, importers must firstly ensure they have the proper mechanisms in place to track (and map) regulatory requirements along the whole supply chain, and then monitor the regulatory world for any changes in those requirements. Secondly, they need to define the supply chain and access data from beyond their broker. This means reaching the manufacturing and processing sites along their supply chain, and this can be a challenge.
Early adopters of the rule have shown that technology can assist with gathering supplier data, mapping the supply chain and managing it on an ongoing basis. Effective supply chain management technology has proved to be helpful in gathering product and supplier data, automating the supplier approval process and managing supply chain management documentation from the actual facility.
Finally, process risks and macro risks can be integrated in the above steps, thus making the risk assessment process a more comprehensive exercise.
SGS FSMA Technical Services
SGS offers a range of services to support facilities, importers and farms, helping them to close compliance gaps resulting from FSMA. Our experts can assist with label compliance reviews, environmental monitoring program (EMP) reviews, Foreign Supplier Verification Program (FSVP) assurance services, onsite and offsite documentation reviews, and product risk reviews. Learn more about SGS’s FSMA Technical Services (link to: http://www.sgs.com/en/agriculture-food/food/technical-solutions/fsma-technical-services)
For further information, please contact:
Global Food Marketing Manager
t: +1 973 461 1498
SGS is the world’s leading inspection, verification, testing and certification company. SGS is recognized as the global benchmark for quality and integrity. With more than 90,000 employees, SGS operates a network of over 2,000 offices and laboratories around the world.