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FSMA Document requests to Warehouses

FSMA warehouse GFSI document requests

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#1 agasr


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Posted 20 April 2016 - 11:30 PM


I work in the storage/distribution industry and have noticed of late that there are a lot of customer requesting documents ranging from Sanitation controls, damage policies etc, Recall plan etc., On an average there is at least 1 such request since March every day. The documents requested are not the same. They all cite FSMA yet, in my review of FSMA there is nothing that talks about documents/programs being need to be shared. It also happens to be the case that the companies are also working towards their GFSI scheme audits. 


It used to be an external (AIB/NSF) audit report in the past, now the request scope has broadened to procedures too that is very varied, which makes it interesting and frustrating at the same time!


In my reading of FSMA as warehouses working with "Unexposed packaged foods" we fit into Modified requirements of PC and need to comply with FSMA's CFR 117 parts etc., To that end, we have been working hard towards that being stronger. 


In my opinion, as a registered facility with FDA, we need to compliant with FSMA on all aspects including making the records available for FDA when the need arises. At the same time, where I am not sure on the need is to share those with other facilities though.


  • Could anyone more conversant with that help me where in FSMA it refers to it to such a need ? I think it is indicated in the FSVP supply chain related requirements, but  that does not apply to us. Hence this questions.
  • Has anyone in this group seen that of late ? How is that getting addressed currently ? Increasing I am thinking of documenting a template clarify our compliance to applicable FSMA's parts instead of the documents .... 

Truly appreciate this group's valuable inputs/experience in addressing the requests





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#2 JPO


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Posted 22 April 2016 - 03:25 PM

Welcome to Preventive Controls in Human Foods!


One of the Preventive Controls measures is "Supply-Chain Preventive Controls" programs. 


As a warehouse, you are definitionally part of the supply chain. IF the people using YOUR services determine through THEIR hazard analysis that YOUR facility and functions may pose a significant risk to THEIR product, they need EVIDENCE that you are adequately minimizing those risks. 


How do they know you are receiving materials properly? Checking for sealed incoming shipments? Checking for damage, signs of pests, correct lots and items received, etc.?


How do they know you have a clean and sanitary facility? How do they know you adequately control for allergen hazards (and other separation concerns like kosher, halal, organic, etc.)


How do they know you pick and pull the right stuff?  Make sure the right things go to the right customers in the right quantities? 


Do you do any relabeling for your customers?  That's a processing step, and often regarded as a critical control point.  How do they know you put the right label on the right bag and didn't introduce a hazard like incorrectly declared allergens at this step?


Do you receive in any damaged or returned from customers items?  How are you managing that?  How do they know that your storage of damage prevents cross contact as well as prevents accidental shipment of on hold items?


(and so on).


Everyone is going to have to get WAY more comfortable in dancing WAY closer.  The only way that you can satisfy the requirements of the customer asking how you do all that stuff up there is to provide them with examples of your programs and evidence that you are DOING all that stuff and doing it RIGHT. 


You will be sending out a metric buttload more documentation.  Also, non-conformances in the supply chain will REQUIRE a WRITTEN root cause analysis as well as a 30 day verification of effectiveness report. 



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#3 Kellio


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Posted 22 April 2016 - 05:32 PM

I will strongly suggest you consider a BRC and IFS for Logistics Certification. I do not recommend SQF Distribution and Packaging though. This is one is not yet perfected. If I am reading correctly, you are subject to Supplier Approval Program Standard and your customers are making sure you ( supplier or supplier of services)  are in compliance with FSMA and GFSI standards. The 2 standards mentioned will alleviate some of the documentation you will be required to provide.


Unfortunately, the documentation request are going to be more and more.


I hope this helps,



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