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