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FSVP - what is needed in addition to HARPC supply-chain program?

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Posted 02 November 2023 - 01:01 PM

Hi all,


We're getting dry seasonings and truffle peels brought in from the Netherlands and Italy, respectively. The dry seasonings make a pit stop in Canada before arriving in the US, the peels come directly here, I think. I was wondering what documentation would be required above and beyond our already established HARPC supply-chain program. For context, we are the consignee of the ingredients and the seasonings and peels will be added to a product post-lethal step.


Also, I was watching a video by FDA talking about verification activities needed for different levels of hazards and they made it seem like if the potential hazard carried a risk of serious illness or death, 3rd party audits and review of food safety documentation wouldn't be an adequate control. If this is the case, is it necessary to do the audit yourself or hire a consultant to do the audit for you and report directly to your company?


- Colby H.


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Posted 03 November 2023 - 03:28 PM

Im guessing that another entity is taking care of the FSVP?  There are verification activities that need to take place for FSVP.   I don't think that i've ever seen anyone /FDA  say that 3rd party audits don't meet at least part of this requirement.   The hope is that the meet some kind of national or global standard (such as GFSI, GAP, etc).  For the most part the FDA has let industry decide what methods they are using for verification.   audits, testing, document review, etc.  


The simple explanation of FSVP is that the importer is assessing the risk of the supplier, assessing the risk of the product imported , and verifying that the risk has been controlled prior to import.   


Even if you are not the importer or acting as the FSVP QI, I think the FSVP course is beneficial to take.  (or at least review the participant manual)

Edited by kingstudruler1, 03 November 2023 - 03:37 PM.




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