Food importers should act now to design, test, and implement foreign supplier verification plans or risk supply chain disruptions, delays in entry processing, and possibly the exclusion of their products from the U.S. marketplace. Domenic Veneziano, independent Food and Drug Administration regulatory and strategic consultant for Sandler, Travis & Rosenberg and previously the FDA’s director of import operations, issued this warning at a Nov. 4 town hall meeting sponsored by the Association of Food Industries in Newark, N.J.
Veneziano offered several tips to help food industry professionals meet the May 2017 FSVP compliance deadline.
– Know if your company or facility is covered by the FSVP requirements. “Many people are under the impression that only the U.S. Customs importer of record is required to comply,” Veneziano said. “But the definition of ‘importer’ under the Food Safety Modernization Act is much broader and can include the actual CBP importer, the owner or consignee of food being offered for import, and even the U.S. agent of the importer. All are at risk if FSVP requirements are not met.”
– The FSVP requirement does not just apply to large food importers. “The statute does make some concessions for smaller companies, but there are still requirements to be met,” Veneziano said. “Unless you meet a specific exemption, your company must create a foreign supplier plan.”
– To create an FSVP that meets government requirements, it is important to understand its purpose. “Under FSMA, importers have explicit responsibility to ensure the safety of imported food,” Veneziano explained. “Foreign suppliers are expected to produce food using the same standards of processing and procedures required by domestic producers. What you want to show the FDA is that you are taking steps to ensure that foreign-produced food is safe and that the food entering U.S. commerce is not adulterated or misbranded.”
– A qualified individual should perform required FSVP activities. “The individual creating the FSVP must have the education, training and/or experience necessary to conduct a sophisticated review of all the records associated with an activity under review,” Veneziano emphasized. “You need an expert who can not only develop the actual program but also conduct hazard analyses, evaluate risks specific to the food being imported, verify supplier activities, monitor corrective actions, and maintain records. It’s a major undertaking and requires a high level of expertise.”