FSVP & Supply Chain Preventive Controls
Development of specific Food Safety programs for Growers, Packers, Shippers, and/or Retailers that do not have a supply chain preventive controls program for their suppliers. Supply chain preventive controls are required for products where YOUR suppliers control the hazards.
FOREIGN SUPPLIER VERIFICATION PROGRAM (FSVP)
The Food and Drug Administration (FDA) has adopted a regulation on Foreign Supplier Verification Program (FSVP) rule applicable to importers of food for humans and animals from foreign countries into the U.S. The regulation requires importers to verify that food they import into the United States is produced in compliance with the hazard analysis and risk-based preventive controls. As well as standards for produce safety provisions of the Federal Food, Drug, and Cosmetic Act (the FD&C Act); is not adulterated, and is not misbranded with respect to food allergen labeling. This regulation is in accordance with the FDA Food Safety Modernization Act (FSMA).
HMP Group, LLC can help on the development and implementation of the Foreign Supplier Verification Program, a few elements included in this program are:
- FSVP Program Development in accordance with 21 CFR Parts 1, 11, and 111 Foreign Supplier Verification Programs for Importers of Food for Humans.
- Conduct a hazard analysis per supplier in order to approve them as foreign suppliers for your organization (Or review and approved suppliers’ existing hazard analysis).
- Perform Evaluation and verifications as determined in the FSVP Program.
- Perform FSVP review and approval process for existing and new, potential, suppliers.
- Maintain a current list of approved FSVP suppliers as required by FDA.
- Support and/or representation during FDA’s FSVP audits.
As required by FDA; a qualified individual will develop the FSVP and perform each of the activities required under this subpart. HMP Group, LLC will assign a qualified individual for the FSVP Program. HMP Group, LLC could utilize its platform https://hmpgroup.net to store and manage documentation relevant to your FSVP Program.
FOOD SAFETY SUPPLY CHAIN PREVENTIVE CONTROLS
The Preventive Controls for Human Foods Regulation requires food companies to develop and implement a risk-based Food Safety Plan.
In this Food Safety Plan, companies must conduct a hazard analysis, determine potential hazards and implement preventive controls that will prevent, reduce or eliminate those hazards. Additional controls must also be considered, including sanitation preventive controls, allergen preventive controls and supply chain preventive controls. A recall plan is also required.
A Food Safety Program is a set of requirements that will include all the above and can be tailored based on your specific needs for you and or for your suppliers in order to assure the safe production and manufacturing of your product.
Food Safety Manual development, implementation, review & updates as needed to comply with the a GFSI Certification.
Maintain an updated Food Safety Program for you or for your suppliers that will include: records, logs, Policies, Procedures, HACCP program, and Lab Analysis available at all times.
Implement Suppliers Control (All Suppliers, Products, Materials and Services), such as:
- On site visits/Inspections
- Development and Implementation of a Microbial Water Quality Profile (FSMA Produce Safety Rule requirement)
- Water Sampling (all wells – quarterly –if applicable)
- Internal full inspections for each ranch or facility –Current Version
- Employee training, as needed, on all topics related to Food Safety
- Audit representation – Representing our clients during the third-party PrimusGFS audits
- FDA – FSMA Produce Safety Rule & Preventive Controls Compliance
If you want to read the requirements for supplier verification, find Subpart G in the Preventive Controls for Human Food rule. However, I recommend starting with the FDA At-a-glance document which provides a neat summary of the rule.