How can I be in compliance with a foreign animal food manufacturer (>500 full time employees) for the FSVP on May 30, 2017 if they do not need to be in compliance with the Preventive Controls for Animal Food until September 17, 2017? Now I understand that the manufacturer would need to be in compliance with the CGMP portion since September 17, 2016, but that doesn't help with verifying preventive controls that the manufacturer doesn't have documentation for. Per below:
FSVP importer of animal food whose foreign supplier is subject to the current good manufacturing practices (“CGMP”) requirements in subpart B of 21 CFR part 507 in the PC rule for animal food. Compliance dates when foreign suppliers are in these categories:
“All Other” Businesses: May 30, 2017
There is a deadline of March 19, 2018, but that is only applicable when the facility does not to be in compliance with the CGMP portion. This I think only applies to facilities that process both human and animal food as being in compliance with the CGMPs for human food can cover the CGMPs for animal food. Per below:
FSVP importer whose foreign supplier is required to comply with the animal food preventive controls requirements in subpart C of part 507 of the PC rule for animal food, but that is not required to comply with the CGMP requirements in subpart B of 21 CFR part 507. Compliance dates when foreign suppliers are in these categories:
- “All Other” Businesses: March 19, 2018
Would this mean just getting a statement that the supplier has CGMPs in place, but I would not be conducting a hazard analysis/verification activities? Any clarification would be much appreciated.
Links:
Animal Food: https://www.fda.gov/...ompliance_Dates
FSVP Compliance Dates: https://www.fda.gov/...A/ucm503822.htm