In today’s world the food we eat can be made in another corner of the world. Food manufacturing facilities tend to have a diversified supply chain including suppliers in distant foreign countries. When building an effective food safety system, we must not forget about proper controls for suppliers of ingredients. Th expectation is that the same food safety standard is met by all suppliers of high-risk food regardless of where it is made.
Traditionally HACCP focused on the process with little to no attention to other aspects of the food safety system. Today’s food safety standards require consideration of other controls including allergens, sanitation and suppliers. Modern approach in food safety emphasizes understanding of the source of food safety hazards and determining who is responsible for controlling and mitigating the risk.
It turns out that food facilities control most but not all the food safety hazards. There are instances where a food facility must rely on their suppliers to properly control significant food safety risks. To simplify, think about an example of a bakery that makes cookies with peanut butter filling. The bakery makes the dough from raw materials and bakes the cookies. The bakery is the one controlling biological hazard through their baking step. Peanut butter filling is applied after the baking and peanut butter is made by someone else. The supplier of peanut butter is the one who roasts the peanuts and makes the butter. The supplier is responsible for controlling biological hazards in their finished product.
This means that the bakery would need to establish appropriate supply chain controls to ensure peanut butter they buy is free from Salmonella and other food safety hazards.
Building an effective Supplier Approval Program requires thorough analysis and a good understating of supplier’s programs, practices and processes. This is not an easy task as in most cases manufacturing facilities don’t regularly visit their suppliers. Looking at food safety standards such as regulatory requirements and private 3rd party certification audits, it is expected that manufacturing facilities and even importers of food ensure safety of incoming products through variety of verification activities.
Before verification activities can be applied suppliers must be evaluated and approved. When selecting a supplier, the receiving facility must be aware of how they manage food safety. In the evaluation process you should look at supplier’s procedures, practices and compliance history with regulatory agencies (FDA and USDA). Evaluation should aim assessment of processes / practices specific to the nature of the food safety hazard you expect your supplier to control. The question to ask is “Is this supplier capable of controlling and mitigating food safety hazards”.
Evaluation is initial and should be repeated periodically. According to Preventive Controls for Human Food regulation, your suppliers must be reevaluated at least every 3 years. In between the evaluation and reevaluation, a receiving facility must verify their suppliers. The purpose of verification is to ensure that your suppliers control food safety hazards on continuous basis. Verification can be done using one or more of the following methods:
- Onsite audits (including the 3rd party audits).
- Sampling and testing for a specific organism of interest.
- Record Review for specific controls applied to control the hazard.
Receiving facilities must decide whether one or multiple verification activities are needed and what those activities are. FDA determined that the default verification for serious hazards (referred to as SAHCODHA hazards meaning the ones that have the potential to cause Serious Adverse Health Consequence or Death to Humans and Animals) is an onsite audit. Example of those hazards are vegetative and spore forming pathogens. Beyond that the facilities must determine and justify the selection of appropriate verification activities.
There is a difference in regulatory requirements under FSMA’s Preventive Controls regulation and 3rd party audits. Under FSMA the primary indicator of whether you need supply chain controls is hazard analysis and it is only applied to high-risk ingredients that are used at your facility “as is”. For the same reason FSVP (Foreign Supplier Verification Program) requires those elements for all imported foods as foreign suppliers control the hazards and not the importing firms.
3rd party auditing standards expect that you conduct a risk assessment on all suppliers. Based on the assessment you will decide on the level of controls for low, medium and high-risk suppliers. Other standards include having a list of approved suppliers, receiving procedures for ingredients with records or scoring suppliers on annual basis based on their performance.
As a food manufacturing / processing facility you must include appropriate supply chain controls as part of your food safety plan or pre-requisite program. Understanding who controls the hazard is essential to ensuring proper verification activities are applied to entities who control the hazards.
Here at BD Food Safety Consultants LLC, we help the companies to design their food safety systems compliant with desired standards. Our team of experts can help design an adequate Supply Chain Program to ensure safety of incoming ingredients. Contact us at https://bdfoodsafety.com/contact-us/ or email at bartdobek@bdfoodsafety.com