Have you ever wondered how safe foods are made in a foreign country? Our market is full of products made in the farthest corners of the world. In today’s globalized economy, food and other commodities can travel long distances.
Prior to 2015 and release of regulations under Food Safety Modernization Act, the controls and assurances that foreign food is safe were very limited and practically nonexistent. FDA was sampling and testing approximately 2% of all imported foods but this wasn’t enough to prevent significant food safety issues. FDA would go out and try to inspect foreign facilities but with an inaccurate database this process was also challenging.
Today under the Food Safety Modernization Act and Foreign Supplier Verification Program the primary responsibility for ensuring safety of imported foods was shifted to the importers.
Of course, this doesn’t mean that the foreign suppliers are not responsible for making safe food. Foreign suppliers must register with the FDA and re-register every 2 years as domestic facilities. Foreign facilities must also comply with all other US legislative requirements and make food under the same food safety standard as US facilities.
Within the Foreign Supplier Verification Program, the importer must obtain DUNS number and use it for identification when completing CBP filing for importation of food products. Importers are also required to conduct several activities that ensure the food they import provides the same level of public health protection as the US products. Importers’ responsibilities are:
- Conduct Hazard Analysis – recognize potential hazards related to the imported food and foreign supplier’s facility. Analyze the potential severity of health consequences if hazards are not controlled and the likelihood of the occurrence for those hazards in suppliers’ facility.
- Evaluate and approve their foreign suppliers – process of evaluation is related to the outcome of hazards analysis. If the importer decided that some of the potential food safety hazards in food they import are significant and require supplier’s control, then supplier’s food safety system must be evaluated to determine that those hazards can be effectively controlled. The results of the evaluation will be used to approve (or disapprove the foreign supplier). Please note that food can be imported only from approved foreign suppliers.
- Determine, conduct and document supplier verification activities – the purpose of verification activities is to ensure that foreign supplier is controlling significant hazards on ongoing basis. The regulation gives the importer some flexibility in verification. Onsite audits, sampling and testing or review of relevant food safety records can be appropriate in verifying suppliers. The type of verification activity will depend on the nature of the hazard and results of supplier’s evaluation. An importer can select one or more of those verification activities.
- Reanalyze the FSVP plan – FSVP regulation requires reanalysis at least every 3 years or whenever there is a reason. There are several factors that may trigger more frequent analysis. Those include food safety hazard discovered in imported food, changes in suppliers’ process or their food safety system, product recalls in supplier’s product or similar products from other suppliers, new scientific evidence pertaining to food safety hazard or controls used by the supplier to control the hazard.
- Develop written procedures for using approved suppliers, receiving procedures, verification procedures and corrective actions procedures.
Food importers must effectively maintain their FSVP, which means they must stay up to date on the recent developments in food safety. This regulation requires the importers to have qualified individual (QI) or individuals that will conduct all required activities. A Qualified Individual is someone who has education, training, experience or combination of those to complete required tasks.
Based on the results of FDA regulatory inspections it appears that many importers still struggle with meeting the FSVP regulation. To assist the industry with implementation of the FSMA rules including FSVP; FSPCA (Food Safety Preventive Controls Alliance) developed training curriculum. It is a 1.5-day training course that teaches the FSVP expectations and provides sample forms that can be used to build an FSVP. Importers can also reach outside of their companies and hire a subject matter expert or consultant for assistance.
Here at BD Food Safety Consultants LLC, we offer FSVP training and FSVP consulting services. Our training course is conducted in online live format and is an interactive course. More information along with dates and registration can be found HERE. For consulting services please email training@bdfoodsafety.com