AIB’s Global Innovation Manager, Dr. Cornelius Hugo, 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 past few weeks, we've been doing a series of FSMA/FSVP questions and answers with Dr. Hugo. Part 1. Part 2. Part 3. Part 4. Here is the final set of five questions:
1. Q: We have so many suppliers. We will need to utilize third party auditors in some cases. What auditing companies are approved by the FDA?
A: I have a lot of empathy for you! The use of third party auditors is fine as long as such professionals are qualified as defined in the rule. FDA does not approve such companies, except for the Voluntary Qualified Importer Program (VQIP), which has not yet been finalized.
2. Q: Do frozen vegetables receive a hazard analysis exception?
A: Frozen vegetable are considered a processed food and would be subject to hazard analysis as per HARPC.
3. Q: If I attend training, will I become certified or qualified?
A: FSMA does not apply the certified criteria; it utilizes “qualified individual”. Per that definition, an employee is considered qualified for their position when appropriate training and experience can be demonstrated. The training qualifications will depend on the position of the employee, and vary for line personnel, supervisory positions, and the PCQI. One way to get training qualifications is to be trained for the specific food safety competencies required for a given position. This applies to line positions and supervisory roles. For the PCQI, one can opt to take the FSPCA/FDA course or show proof of training from other equivalent sources. Experience is simply accumulated throughout your career.
4. Q: If a supplier is on an import alert “green list” such as soft cheese from France, can that serve as proof of a supplier evaluation and compliance?
A: The “green list” applies only to the product and not the supplier of such product. Foreign suppliers would still be subject to the FSVP, in my opinion. However, this is a question worth sending directly to the FDA.
5. Q: We import a plant product that is processed and sent to us in powdered form. Is this covered under produce safety?
A: From your description, I assume you are describing a product that has been harvested, selected, cleaned, dried, and milled to obtain the right powdered consistency, and then packed for shipment. If this description is correct, then this product would not fall under the produce rule. The produce rule applies only to raw agricultural commodities which are consumed in their raw state. Your supplier should be subject to the FSVP, and the farms supplying the raw product should be applying gaps.
There you have it! If you found this useful, check out the earlier installments. If you have FSMA questions that weren't covered, check out 5 Steps to a FSMA-Ready Facility for more ideas and information!