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FSVP Assessing Foreign Supplier's Hazard Analysis

FSVP

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#1 assila91

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Posted 07 July 2017 - 06:57 PM

We are an import company (Wholesale/Distribution) which we import many different types of products such as frozen noodles, miso (soybean paste), soy sauce, seasoning bases, soup stocks, RTE frozen products, etc.

 

As we have hundreds of foreign suppliers, we have opt to review the supplier's HACCP plan but from there, I am not sure of how to efficiently assess whether if all the known or reasonably foreseeable hazards has been addressed as the format is slightly different than the HARPC. 

 

I have worked with this company for couple years maintaining seafood HACCP for our facility and have taken PCQI training and attended FSVP seminar.

However, I feel like I am still lacking knowledge on how to successfully be in compliant with the FSVP rule. My question is, how are we supposed to assess products that we are not familiar with what hazards are associated with the product? 

 

 

 

Any advice would help. 

Thanks!

  

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#2 silviakahn

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Posted 12 July 2017 - 08:39 PM

Hello Assila91,

 

What I did was to check if my vendor's HACCP plan addressed the hazards identified by the FDA Draft Guidance for industry (https://www.fda.gov/...A/UCM517402.pdf). Also, I did a search in google to see if the country where my vendor was located had been linked to any Economically Motivated Adulteration (EMA) hazard and to any radiological hazard. If the vendor didn't address these hazards, I would start asking for support documentation indicating why that hazard was not likely to occur. 

 

This is what I did. Hope this helps!

 

Silvia


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#3 Charles.C

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Posted 13 July 2017 - 05:41 AM

Hello Assila91,

 

What I did was to check if my vendor's HACCP plan addressed the hazards identified by the FDA Draft Guidance for industry (https://www.fda.gov/...A/UCM517402.pdf). Also, I did a search in google to see if the country where my vendor was located had been linked to any Economically Motivated Adulteration (EMA) hazard and to any radiological hazard. If the vendor didn't address these hazards, I would start asking for support documentation indicating why that hazard was not likely to occur. 

 

This is what I did. Hope this helps!

 

Silvia

 

Seems a logical approach although i note that every page has the header -
 

 

Contains Non-binding Recommendations
Draft-Not for Implementation

 

 

@assila - One obvious difficulty is your Excel uses the popular "pathogens" as a hazard. This seems incompatible with the FDA Draft.

 

Looks like you may have need of a haccp team.


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Kind Regards,

 

Charles.C


#4 silviakahn

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Posted 13 July 2017 - 01:44 PM

Yes, I noticed that. I think it has that header because it is only a draft. However, I think it is a good source until something better gets published. 


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#5 Charles.C

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Posted 13 July 2017 - 02:42 PM

Yes, I noticed that. I think it has that header because it is only a draft. However, I think it is a good source until something better gets published. 

 

Hi Silvia,

 

Yes i agree.

Unfortunately the Draft does not (yet?) specify any CCPs as was done for their Seafood HACCP Guidance . The Draft does have a huge scope of course.

 

@assila - I found the "fresh" name of the  product rather odd inasmuch as  it is boiled and "sterilized(?)".  Maybe these names/terminologies are traditional to the noodle industry.

I have no idea re-FSMA expectations but i generally quite liked yr flowchart, hazard analysis (not my customary format but I know is US-popular) etc although i thought the text in some columns maybe over-abbreviated. I  would have made the final allergen labelling step a CCP unless already categorized as a PRP. It's a matter of (FSMA?) opinion of course.


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Kind Regards,

 

Charles.C






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