AIB’s Global Innovation Manager, Dr. Cornelius Hugo, recently led a webinar about the FSMA Foreign Supplier Verification Program for the International Food Safety and Quality Network as part of their excellent Food Safety Fridays series.
Questions poured in from attendees following the webinar. We're betting that if someone asked a question, lots of you might benefit from the answer. So, over the next few weeks, we'll be doing a series of FSMA/FSVP questions and answers with Dr. Hugo. Part 1 is here. Here are the second five:
1. Q: So is seafood still subject to the same rules as before?
A: Correct. Seafood will still be subject to the Seafood HACCP. The importer will have to 1) review such HACCP Plan for completeness, 2) review the compliance history of the supplier, and 3) undertake the appropriate verification activities and frequencies to assure compliance by the foreign supplier.
2. Q: Are suppliers from foreign suppliers expected to follow HARPC or FSMA as well? We are exported to the U.S… Are our suppliers expected to be HARPC compliant as well?
A: All foreign suppliers are subject to FSMA. HARPC is one of the rules under FSMA. The importer in the US is responsible to assure that their foreign suppliers have undertaken a HARPC analysis in order to establish if there are “hazards needing a preventive control” and if so, who will control such hazard: the foreign supplier, the local supplier to the foreign supplier, or the importer. In short, the importer is responsible for ensuring that all foreign suppliers have undertaken a HARPC analysis to define what preventive controls will be applied and by whom in the food supply chain. The importer is also responsible for reviewing the compliance history of its foreign supplier in order to approve or disapprove supplier.
3. Q: Are GFSI recognized schemes compliant with the requirements of FSMA?
A: I am sure all of them will comply with FSMA requirements, otherwise their value will be diminished. Make sure your certification body provides you written evidence how its scheme meets all applicable FSMA requirements.
4. Q: What about qualifications of people doing verification? Do they need official training? Any kind of approval? Could it be done by a food consultant? Do they need to be from the US? And if the foreign food embellishment is already approved by US authorities, is verification still necessary?
A: A great many questions! The Preventive Controls Rule for Human Food contains a definition about “Qualified Individual”. This definition states that each employee must be qualified to undertake his/her duties to ensure the production of safe food. So each position needs to be evaluated and personnel trained accordingly. This applies to line personnel, supervisory personnel, and to the Preventive Controls Qualified Individual (PCQI) who will be responsible for the development, implementation, management, and reanalysis of the plan. The PCQI does not have to be an employee of the plant, does not have to be from the US. Verification will still be necessary since this is an internal requirement of the foreign supplier to demonstrate the Food Safety Plan is being carried out as designed and is effective.
5. Q: Do original records need to be sent to importer by the manufacturer?
A: No. However, true copies of such records must be made available for verification activities such as record reviews. Or, the importer must have access electronically to such records. For example, the importer has to review the Food Safety Plan of his foreign supplier. Such plan can be submitted electronically, or electronically to the importer for review and assessment. Or it can be reviewed by a third party, however, the importer must assess the results of such review and document such activity.
And a bonus question:
6. Q: Our supplier is organic certified, does this help?
A: No. Organic is not a criteria covered under FSMA.
There you have it! If you found this useful, check out part 3 and stay tuned for parts 4 and 5 of this series. In the mean time, if you have FSMA questions that just can't wait, we have 5 Steps to a FSMA-Ready Facility ready for you!