Do you buy raw materials, ingredients, or food contact substances from an importer? What verification activities should you undertake to ensure such imported inputs are in compliance?
Today's tip is about verification activities you might consider implementing if you source raw materials, ingredients, or food contact substances from an importer. You could rely on the importer to ensure that the purchased imported products meet regulatory requirements for safety. Or, you could be more proactive and implement certain verification activities to ensure food safety and comply with regulatory requirements. Obviously, the second approach seems more robust from an assurance and a regulatory point of view.
The verification activities you undertake to ensure the importer is complying with the FSVP may be quite similar to activities you are doing already. Consider asking these questions:
- Has the importer registered with the FDA?
- Has the importer carried out HARPC analyses of the imported products, as well as evaluations of compliance histories of the foreign suppliers that export the products you are buying from the importer?
- Has the importer approved the foreign suppliers and is documentation available to demonstrate products are being received from approved foreign suppliers?
- If a product was imported from a non-approved supplier temporarily, did the importer carry out appropriate product and supplier verification activities prior to importing the product?
- Is the importer carrying out verification activities as written, in the frequency called for, reviewing and documenting results?
- Is the on-site audit for SAHCODHA hazards being done annually? What have been the outcomes and how have non-conformances been addressed?
- Have there been any on-site audits for non-SAHCODHA hazards?
- Has sampling and testing been carried out as planned? Have there been any issues? If so, how have they been addressed and communicated?
- What have been the results of review of relevant food safety documentation of foreign suppliers, and how have non-conformances addressed?
- If a foreign supplier depends on a local supplier to control an identified hazard requiring a preventive control, has the importer verified that the foreign supplier is carrying out appropriate verification activities of the local supplier?
- Have corrections and corrective actions been verified for effectiveness? Any repeat issues?
- What have been the results of regulatory and independent/private audits and have non-conformances been addressed?
- Are all employees requiring a “qualified individual” rating trained to that level, including line personnel, supervisory level and the Preventive Controls Qualified Individual?
- Has the importer used qualified individuals to undertake the HARPC analyses, complete the suppliers’ compliance histories evaluations, develop, implement and re-evaluate the FSVP, and audit foreign suppliers?
- Is the importer maintaining appropriate records as required by the FSVP?
An annual review of these verification activities carried out by the importer who is supplying you with imported products will go a long way to ensuring that you are being provided with clean, safe and legal products.