The Food Safety Modernization Act
Back in 2011, President Barack Obama signed the Food Safety Modernization Act (FSMA) into law after alarming figures surfaced surrounding the monitoring of food safety. The Centre for Disease Control and Prevention found that foodborne diseases were the cause of 1 in 6 Americans (48 million) falling ill, the hospitilization of 128,000 people, as well as 3,000 deaths annually across the United States.
The introduction of FSMA was a crucial development in the American Food & Drug Administration’s (FDA) response to the realization that these crippling illnesses were preventable. Moving from a reactive approach to a proactive approach, the act recognized the importance of a united approach across all points in the global food supply chain, for all products manufactured towards both human and animal consumption.
FSMA applies to a broad category of food organizations, from manufacturing and processing to distribution, packaging and storage. As part of this effort to optimize food safety, the FDA also identified and implemented a number of rules regarding importation. The aim of which is to protect the population from any outside threats.
What Importers Need to Know About FSVP
The FSMA initiative in place for ensuring the safe importation of food products into the US is known as the Foreign Supplier Verification Program. This initiative affects importers and agents of international companies, as well as the transporters and carriers of the food and beverage products. FSVP was introduced to provide assurance that all imported food is safe for consumption and adheres to standards for public health protection. As part of this initiative, the importer must also identify potential violations, such as product mislabelling or adulteration.
It is important to consider the mandatory nature of the Foreign Supplier Verification Program. In the same way that a person arriving into the United States from another country requires a passport upon entry. All food and beverage products must meet the requirements of FSVP or the import will not make it into the United States.
With the large volumes of imported food arriving into the US every day, FSVP monitors the safety of each and every item, appointing a consignee. This may also be known as the US owner of the particular food item(s); an individual who has purchased and legally signed for the imported goods and can be accounted for as the US owner/consignee.
Developing a Plan to Ensure FSVP Compliance
In the case of FSVP for food importers, the consequences of non-compliance are not taken lightly. Within the first year of mandatory compliance with the legislation, FDA inspectors uncovered 108 failures among importers. In the long term, failure to comply can result in fines, damaged reputation, refusal of your products on entry, and potentially business collapse.
If your organization imports food products, it’s essential you develop a risk-based FSVP plan as soon as possible, helping you identify hazards concerning the goods you import. When developing a plan consider the following:
1) Evaluate food risk and supplier performance based on hazard analysis and past compliance performance
2) Carefully approve new suppliers and determine appropriate supplier verification activities based on their processes and food safety practices
3) Conduct corrective actions in response to identified hazards, this responsibility is shared by both you and your supplier
4) Conduct re-evaluations regularly on previously approved suppliers, the FDA expect annual on-site audits
With ever-changing food safety regulations being introduced to the industry, monitoring and management can seem like a challenge. However, FSVP is a mandatory requirement you cannot afford to overlook.
Ensuring FSVP Supplier Compliance With AuditComply
The question remains, how should you proceed? After establishing a qualified individual, who has the education, training and experience to perform such activities, you need to determine how you’re going to manage the FSVP program across your supply chain. Providing assurance that hazards identified are being prevented.
To help ease monitoring, you should think about moving towards a GRC Food & Beverage Management platform. Making it easier to assess, manage and report on supplier compliance across your supply chain.
AuditComply provides dedicated supplier portals that allow you to communicate with suppliers at any given moment. If your supplier has already conducted a hazard analysis you can request this document right from your office, remotely. If not, then you can conduct a hazard analysis to determine whether there are any hazards requiring a control. If no hazards are identified which require preventive control, then no verification is required. However, you must have a hazard analysis on file to show that this has been determined.
Remember, it’s not enough to simply collect these documents from your international suppliers – you have to assess and document that assessment process. AuditComply will automate this approach with configurable workflows, template builders and supplier portals; from the initial assessment to the raising of issues and management of controls. Providing confidence at any given moment, that your suppliers are compliant with local legislation.
AuditComply for Food & Beverage
AuditComply is designed by FSQA & Production Managers to meet the challenges of modern food organizations, from manufacturing to food processing and distribution. Whether it’s the ongoing labor shortage, requiring you to do more with less, the increasing risk of contamination in the supply chain, or the spiraling complexity of operations, AuditComply delivers a company-wide focus on safety, quality and compliance. Driving reassurance across the industry that your team is delivering the freshest, highest quality, sustainable food products.
We are your food organization’s backbone, protecting revenue, reputation, sustainability & governance. In one easy-to-use platform, users can assess, manage and report in real-time on internal FSQA standards (SQF, GFSI, FSMA, HACCP, ISO), supplier compliance and legislative requirements. Streamlined non-conformance workflows, photographic evidence collection, paired with built- in communications and automated task scheduling provide greater control and visibility. We are a mobile paperless solution that assures quality and compliance across all your locations without the need for manual record-keeping.
If you’re interested in learning more about AuditComply, you can request a demo here, we’d love to show you how we can help you ensure supplier compliance across your food business.