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. Part 2. Here is the third set of five questions:
1. Q: What about further processing? What is the definition of this exception?
A: Related to the definition of a foreign supplier, then “further processing” implies that the supplier is that entity which ships a product that will not underdo any other processing by another entity before it is exported. The only exception is the “minimis” kind of additional handling such as labeling for retail at a later stage. That is allowed since such activity will not change or alter the product.
2. Q: If my supplier is SQF certified, does it comply with the foreign supplier verification program?
A: Yes, as long as the SQF scheme addresses all the requirements of FSMA, and the auditor is a “qualified auditor”. It would to wise to address this question with your certification body and obtain such assurance in writing.
3. Q: Are there some third party companies certified to do risk based hazardous analysis for importers?
A: The answer is yes. However, the rule does not require that the person doing the risk analysis or doing the audit of the food safety plan of the foreign supplier be “certified”. The rule requires that such professional be a “qualified individual”. If such a professional works for a certification body doing work in food safety, such professional could demonstrate his/her qualifications based on his/her training and experience.
4. Q: Does the foreign supplier verification program apply to food contact substances (resins, films, flexible plastic packaging)?
A: Yes. Under the foreign supplier verification program, the definition of food includes such substances.
5. Q: So the unique ID is the ID of the importer? Is this then equivalent of the license that was used to import the product? Still trying to understand how the importer is determined.
A: The importer can be the 1) the owner of the product (the person who bought the product for import into the US), 2) the consignee (the person who will be officially receiving the imported product in the US), or 3) the agent of the foreign supplier in the US who is legally representing the foreign supplier. By unique number it is implied that such ID is related to a specific person/location where the product can be traced to. I would suggest you ask the FDA whether the import license can be such specific ID.
OK, just one more. A spring bonus!
Q: What can I do to evaluate food safety issues at my plant?
A: AIB has developed a FSMA Readiness Assessment which covers all requirements in the HARPC and FSVP rules. The assessment identifies needed improvements in order to meet the requirements of these two regulations.
There you have it! If you found this useful, check out the earlier installments 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 waiting just for you!