26 replies to this topic

[TimG]

I've been in food for a while, and none of the previous entities I've worked at had an issue providing customers their FDA registration #. The corporation I currently work for has 2 strong supporters of "don't ever give that out, it's like a SS#," both saying they learned in various training classes that it was a very bad idea to give out the FDA reg #. 80% of the questionnaires that pass my desk request an FDA reg #, which I have no problem instructing to be filled in as 'proprietary.' Do you folks provide them to customers, or lock them up?

[Setanta]

Like SS numbers, I give out the last 4 digits.

[MDDF]

If you have an NDA with me, yes.  To any other customer, no.

[mgourley]

We provide the last 4 only.

 

Marshall

[Ryan M.]

No.  We provide a letter stating we are an FDA registered facility and maintain the registration.

 

From what I was told someone can use your FDA registration number fraudulently to import / export goods, and also to manufacture and/or handle food on "your behalf."

[kettlecorn]

No.  We provide a letter stating we are an FDA registered facility and maintain the registration.

 

From what I was told someone can use your FDA registration number fraudulently to import / export goods, and also to manufacture and/or handle food on "your behalf."

 

I've heard this too, but I was told by someone who I consider a credible source that it's just a myth. I've never seen a definitive answer in writing by the FDA. 

[TaraMcKinzie]

I was advised by  our NSF cGMP Auditor to never give out the actual number so I have always told our Sales Manager no when she asked for it to give to a perspective customer.  Once they are established customers I go on a more case by case basis.

[SQFconsultant]

Have always given it out ans without issue.

[TaraMcKinzie]

I was looking forward to your response.  Thank you.

 

Have always given it out ans without issue.

[TimG]

So we're about where we were 4 or so years ago when this topic was last brought up. I will continue to not supply it (I have a blacked out application document like was suggested in the 4 year old thread) but I don't think some evil entity could use a FDA reg and bring down civilization as we know it. I was hoping to get some type of concrete reason why and I was bored on a Friday before the 3 day weekend.

[PieGuy191]

I have always used this from the Bioterrorism Act rule to explain why we do not give out the number:

 

"FDA's list of registered facilities and registration documents submitted to FDA are not subject to disclosure under the Freedom of Information Act. In addition, any information derived from the agency's list or registration documents that would disclose the identity or location of a specific registered person is not subject to disclosure." 

[deutscheli]

When Exporting to the US often the importer needs the registration # so I do give the # itself but never show the copy of the registration since the PIN is and needs to be extremely confidential. 

 

Eli

[YNA QA]

We've always given out the last 4 and no one has ever had an issue.

If they require further info, I scan the registration page with the beginning of the number blacked out, so that we can use that as further confirmation.

[srhodes]

We have a statement that that we put our FDA# as such XXXXXXX0011.

[Lynx42]

I was told by 2 auditors (one SQF) to only share the last 4-digits and to ensure the PIN is fully blacked out.  

[TimG]

I was told by 2 auditors (one SQF) to only share the last 4-digits and to ensure the PIN is fully blacked out.  

This seems to have emerged as best practice. I have a statement on company letterhead stating the date we re-registered along with the last 4 of our pin and then signed by myself.

[kconf]

Just the last 4. 

[jfrey123]

This thread bumped probably because someone voted in the poll, but it's timely because FDA just today released some more guidance on registration numbers.  They themselves are highlighting, yet again, the need to protect your number to prevent it being used fraudulently.

 

FDA Advises Human and Animal Food Facilities to Protect their Food Facility Registration Information | FDA

 

The FDA has become aware of a number of issues regarding when registration is required and potential misuse of FFR, including:

• An uptick in businesses registering their facilities with the FDA when they are not required to. 
• Third-party businesses or "registrars" requesting FFR number, PIN, FIS-FURLS username, and/or FIS-FURLS password to verify registration status.
• The TikTok Shop and other third-party seller platforms asking food companies to provide a copy of their FDA Food Facility Registration, or a certificate, as part of their product-listing process. 

The above issues can create problems for both these businesses and for the FDA, including:

• Security Risks: Having an FFR number when you don't need one, and then sharing it with third-party platforms, creates opportunities for bad actors to misuse your registration information for fraudulent purposes. When you provide your FFR number and PIN (or username and password), these entities can link your FFR to their own FIS-FURLS accounts. Once linked, they can view, change, or even cancel your FFR.  To check your FFR status always use the official FDA website here.
• Regulatory Confusion: Registering when exempt or otherwise not required to may subject your facility to unnecessary inspections or create confusion about your compliance obligations.  
• Straining FDA Resources: Unnecessary registrations divert FDA resources away from monitoring facilities that are required to register, including those that pose increased food safety risks. 

[GMO]

Daft question? Why?

In the UK we have health marks for meat and dairy products and they are literally on pack. Isn't it more of a fraud issue if someone cannot check you are approved?

[jfrey123]

In the US, our USDA regulated sites for meat, poultry and eggs have establishment numbers that are on the packaging like you describe.

 

Under FDA, the Bioterrorism Act of 2002 required all food manufacturers/handlers to get unique registration numbers.  It's primarily a number the Federal government is supposed to use to track activities like imports/exports, listing sites where food can be held (therefore targeted for bioterrorism), etc.  It's not intended to be a publicly facing library for public data.  Having the full number out and about permits other businesses and entities to act as you on official paperwork.

[TimG]

Wow this was a blast from the past. I no longer give my full # out though, I just give the last 4 and the month/year it was renewed.

[G M]

Daft question? Why?

In the UK we have health marks for meat and dairy products and they are literally on pack. Isn't it more of a fraud issue if someone cannot check you are approved?

 

Like a lot of things, the USDA has a process that makes sense, the FDA does not.

 

Some food related establishments are required to register with the FDA for various reasons, but who and why is clear as mud. The only ones the FDA envisioned ever knowing this registration number were the company itself, and the FDA -- but lots of retailers and large companies will still ask for it form their suppliers and partners, even though you can't look the number up in any kind of FDA registry to see if its legit or up to date ~ so it's kind of pointless. To top this off the only official document that shows this number also shows other confidential information, so if you do share it and you're not careful, you've basically handing over your companies account information with the FDA.

 

All facilities processing USDA regulated/inspected products are registered and given an establishment number that is public information along with some other basic location details, and this number is required to be on packages of your product, so in the event of recalls and the like it is clear where something was made, regardless of what brand or product name is on the package.

[AtomicDancer]

Yet it is required on international shipping documentation. 

[TimG]

New supplier just sent me their full registration page, WITH THE COPY OF THEIR FACILITY REG # and PIN# ON IT!!!

 

I feel like I should call their QA department and tell them that's probably not a good idea to give that out... 

[jcieslowski]

I never used to give it out.  Like many of you, I was told it was basically the key to the whole business.  I've since heard, like some of you, it's not that serious.  The company I'm at now has always provided (but not the pin lol)