Jump to content

  • Quick Navigation
Photo
- - - - -

What are the relevant food safety records of a foreign supplier?


  • You cannot start a new topic
  • Please log in to reply
5 replies to this topic

kss151

    Grade - Active

  • IFSQN Active
  • 9 posts
  • 0 thanks
1
Neutral

  • United States
    United States

Posted 08 February 2019 - 08:30 PM

Hello - My company imports some simple polyols and alternative sweeteners and I am responsible for FSVP. I have now gone through two separate FDA inspections for my FSVP programs and passed both with no issues, but something is bugging me when going back and reviewing the rule, that I might be missing:

 

When the rule says that you must review the supplier's relevant food safety records, what exactly is it talking about there? I believe I was told one time that it is not referring to things such as processing records (if applicable), metal detection sign off forms, etc, but is rather talking about statements and records saying they have these programs in place (which are backed up by their GFSI audit reports)? Personally, I dont see much merit in reviewing sign off forms and actual processing records that are just going to be in a language that I cant read, so I was havent pursued them.

 

Let me know your thoughts. Thank you!


Edited by kss151, 08 February 2019 - 08:31 PM.


SQFconsultant

    SQFconsultant

  • IFSQN Fellow
  • 3,746 posts
  • 943 thanks
829
Excellent

  • United States
    United States
  • Gender:Male
  • Interests:American Patriot
    WWG1WGA
    Never give up, never give in - always win!
    Martha's Vineyard Island, Massachusetts

Posted 08 February 2019 - 08:50 PM

Have you been to your suppliers to audit them or had audits done on your behalf of your foreign suppliers?


Kind regards,
Glenn Oster
 
GOC BUSINESS GROUP | SQF System Development, Implementation & Certification Consultants
Internal Auditor Training - eConsultant Retainer Subscriptions - Pre & Post SQF-GAP Audits - Consultant Training
Visit us @ http://www.GlennOster.com  or call us @ 772.646.4115 US-EST 8am-4pm Anyday except Thursday
 
 

kss151

    Grade - Active

  • IFSQN Active
  • 9 posts
  • 0 thanks
1
Neutral

  • United States
    United States

Posted 08 February 2019 - 08:56 PM

It's been a topic of discussion, but at this time no. A few reasons for that, 1. we are a distributor that is not using these products, 2. We have deemed these products to be low risk, 3. Because we are a distributor, the added cost of hiring a second party auditor to go there could essentially negate the profits we could make by sourcing these products overseas, so it's been tough to get upper management to fully buy in to that. So since we only import through GFSI audited suppliers (that I do verify on each database), we did not deem on site audits to be necessary for a verification activity. 



Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 18,785 posts
  • 5236 thanks
1,215
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 08 February 2019 - 09:28 PM

Will FSMA not accept local 3rd Party audits ?


Kind Regards,

 

Charles.C


kss151

    Grade - Active

  • IFSQN Active
  • 9 posts
  • 0 thanks
1
Neutral

  • United States
    United States

Posted 08 February 2019 - 09:42 PM

They did accept the GFSI audit as part of the verification and accepted our rationale for not getting an independent auditor, and in the inspection, to my memory, they didnt say anything about getting the actual processing or sanitation records (etc) and that the statements were fine. But we all know how it is, maybe one inspector thinks one way of it than the two I got. Was wondering if any of you keep actual records like that in your plans.


Edited by kss151, 08 February 2019 - 09:43 PM.


Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 18,785 posts
  • 5236 thanks
1,215
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 09 February 2019 - 05:19 AM

Hello - My company imports some simple polyols and alternative sweeteners and I am responsible for FSVP. I have now gone through two separate FDA inspections for my FSVP programs and passed both with no issues, but something is bugging me when going back and reviewing the rule, that I might be missing:

 

When the rule says that you must review the supplier's relevant food safety records, what exactly is it talking about there? I believe I was told one time that it is not referring to things such as processing records (if applicable), metal detection sign off forms, etc, but is rather talking about statements and records saying they have these programs in place (which are backed up by their GFSI audit reports)? Personally, I dont see much merit in reviewing sign off forms and actual processing records that are just going to be in a language that I cant read, so I was havent pursued them.

 

Let me know your thoughts. Thank you!

 

What Records Should be Kept?

Any record requested by the FDA must be available within 24 hours and could go two years back. If you don’t have an automated system, it’s likely time to consider one, as it’s really the only way to manage the range of documents required by FSMA across your supplier base. Here are the nine records that should make up your FSVP below.

  1. Hazard Analysis
  2. Foreign supplier Approved list
  3. Foreign supplier performance evaluation
  4. Foreign supplier approval procedures
  5. Procedures assuring only approved foreign suppliers are used
  6. Verification activities & their frequency used to determine approved foreign suppliers
  7. Performance of verification activities
  8. Identified corrective actions needed
  9. Re-evaluation of FSVP by cause, or at least every 3 years

 

 

Attached File  FSVP(1).pdf   319.16KB   52 downloads

Attached File  fsvp(2).pdf   1012.63KB   48 downloads

 

Also see -

 

https://www.fda.gov/...A/ucm361902.htm


Kind Regards,

 

Charles.C





0 user(s) are reading this topic

0 members, 0 guests, 0 anonymous users