My first-time operating a boat was about 10 years ago while visiting a small island in the Gulf of Mexico. My husband had previously worked in the boating industry and understood the basics. I had no real knowledge of how to operate a boat; I didn’t know basic terminology nor have any instincts around boats. Every aspect was foreign to me and to this day, I am still slightly intimidated to take the captain’s chair. My husband has been involved with boats or water safety on and off for over 30 years and has much more knowledge than me, so I rely on him.
Just as I felt on the boat, FSMA (Food Safety Modernization Act) and FSVP (Foreign Supplier Verification Program) Rule can be intimidating and confusing. The terminology and acronyms are new to industry. And we just learned who can be the FSVP Importer. So, as an industry expert, let me break it down simply.
FSVP is a good supplier compliance management program.
Here is what you need to meet law requirements if you are FSVP importer:
- Identify FSVP importer –The only entities to be named as FSVP importer are the US Customer, the US Consignee or a US agent. There must be a conversation with downstream supply chain contacts to determine WHO accepts the FSVP importer responsibilities. If you are the foreign supplier or exporter, do not assume the US Customer accepts the responsibility.
- Establish a Written Plan – this is a Standard Operating Procedure for how your FSVP is managed. Though a part of your Supplier Management program, FSVP should be separate ONLY because you don’t want the entire policy under scrutiny when inspected. You will also want a template to consolidate your verification and evaluation activities onto 1 or 2 documents for easy inspections.
- Hazard Analysis/Verify – food safety hazards for imported food items must be identified and determined if reduced to acceptable levels. If hazards are not mitigated by the foreign supplier(s), the US FSVP importer must ensure controls (e.g. label claims, further processing/treatment, etc.), verifying the product is safe for consumption. This analysis must be done by a QI (qualified individual) knowledgeable in food safety practices and hazards of the foods. Translation to English might be required depending on the QI native language.
- Evaluation – the foreign supplier must be evaluated for applicable US law requirements for each product they produce and appropriate food safety practices eliminating or controlling above identified hazards. They also need checked to be in good standing with the FDA and other regulatory agencies.
- Approved Supplier List – once approved, a list of approved suppliers must be maintained. This can be a list or policy that includes ERP (Enterprise Resource Planning) tools. The supplier must be continuously monitored for food safety incidents.
- Corrective Actions – if a food safety incident (e.g. FDA import alerts, warning letters, recalls, etc.) occurs to the food or foreign supplier, the US FSVP importer must conduct corrective action(s) and determine next steps which might include discontinuing the foreign supplier.
- Record Keeping – YOU MUST maintain the documentation for up to 2 years after import date.
- Re-Evaluate – verification is required every 3 years. (Continuous monitoring is always required).
In summary, the FSVP importer program is easy to manage as part of your Supplier Compliance Management Program. You must have a Qualified Individual (QI) with food safety background involved in the process. If you have not hired a QI, Safe Food En Route, LLC’s CEO/Founder, Jennifer Crandall, has over 20 years of experience in the food industry with extensive background in supplier compliance and assisted one of the largest US Grocery retailers set up their FSVP program.