Specialty Food Magazine is the leading publication for retailers, manufacturers and foodservice professionals in the specialty food trade. It provides news, trends and business-building insights that help readers keep their businesses competitive.
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The first and most important step is to use approved Suppliers. It is your responsibility to approve the Suppliers before you receive the raw ingredient, which can be challenging when you have a multitude of Suppliers and/or switch Suppliers based on ingredi- ent availability and price. FSMA requires written procedures for receiving the ingredients from approved Suppliers, as well as records documenting that the product is safe when it is received. You must conduct verification activities before accepting an ingredient or food from a Supplier. These verification activities can include an on-site audit, sampling and testing by the Supplier or Receiving Facility, and/or a review of the Supplier's food safety records for the ingredient. Once the Supplier has been verified, you can perform these activities less frequently, depending on the safety risk of the raw material. The regulation stipulates various considerations for verification, including the Supplier's procedures, processes, and practices for the safety of the ingredient; past FDA warning letters to the Supplier; the Supplier's corrective actions; and whether the Supplier has good storage and transportation prac- tices. You also need to consider country of origin. It is your responsibility as the Receiving Facility to approve the Supplier. Although the Supplier can send you information regard- ing the safety of its food or ingredients, you must document that the information is accurate and meets your requirements. If a serious health hazard could exist, you are required to initiate an on-site audit using a qualified auditor, who can be a government employee or the agent of an accredited certification body. These audits must occur at least annually and should include both records review and an in-person observation of practices. If you have a PCQI on staff, you can use that person to do the audit. When a gap in supplier performance is identified, you must make sure that the food you have manufactured with that ingredient is not adulterated or contains unidentified allergens. If the food is unsafe, you must have a plan for corrective action and recall. Documentation of Your Supply Chain Program The specialty food industry thrives on innovation. Specialty food manufacturers often change the foods and ingredients used to cre- ate their products. The Supply Chain Program needs to reflect this constant change. Two types of change need to be considered: changes made by the Supplier and/or changes made by the Receiving Facility. When a Supplier makes a change, they must immediately report it to the Receiving Facility so that they can document the change and whether it will impact the Food Safety Plan. More likely, the specialty food manufacturer will choose a new Supplier based on quality, price, availability, or other business fac- tors. These changes must be communicated to the internal Food Safety Team so they can determine whether the new Supplier or ingredient should be controlling a hazard, and then set up a Supply Chain Program to make sure the Supplier complies. FSMA requires documentation of your Supply Chain Program. This must include: • written Supply Chain Program; • for import facilities, Foreign Supplier Verification Program compliance documents; • documentation of Supplier approval; • receiving procedures; • receiving records; • determination of appropriate Supplier verification activities. Importers and the Supply Chain Program Management of the supply chain for importers is similar to that required by domestic manufacturers. The Foreign Supplier Verification Program requires importers to monitor the Food Safety Plans of their foreign suppliers. These Food Safety Plans should have a Supply Chain Program if a hazard is controlled before the food or ingredient arrives at the facility that processess the final product before it is exported. In some circumstances, the importer would implement the preventive control before selling the product to a domestic manu- facturer, i.e., Receiving Facility. In that case, the Receiving Facility would treat the importer as part of its Supply Chain Program. An importer will also be in compliance if the preventive control is imple- mented by the manufacturer purchasing the product, and it verifies that the control is part of its customer's Food Safety Plan. For instance, importers of coffee beans and cocoa beans often purchase from many farms. These products cannot be consumed without further processing that controls hazards. Importers are not required to verify the safety of the supply chain for these products. They do need to make sure that the entities to which they sell the food are controlling the hazard. As the specialty food industry becomes more aware of FSMA and its implications, management of the supply chain is an impor- tant aspect of any company's Food Safety Plan. Ron Tanner is vice president, philanthropy, government, and industry relations for the Specialty Food Association. Every food manufacturer must create a written Food Safety Plan and operate based on that plan. A Preventive Controls Qualified Individual must author the plan. SPRING 2017 87