3 replies to this topic

[QAKat]

Hello All.

Happy Valentine's Day <3 

 

I have a question regarding FSVP.

 

If we receive the HACCP with the hazard analysis from the foreign supplier, do we as the importers still have to conduct a hazard analysis? 

 

I am going to do a training, but it's until the end of March so I am trying to get some info to maybe get started before the training. 

 

Thank you!

[Tony-C]

Hi QAKat,

 

For your Hazard Analysis question, see (d) Review of another entity's hazard analysis. 

 

Title 21 Food and Drugs Chapter I Subchapter A Part 1 Subpart L Foreign Supplier Verification Programs for Food Importers 1.500 – 1.514

 

1.504 What hazard analysis must I conduct?

 

(d) Review of another entity's hazard analysis.  If another entity (including your foreign supplier) has, using a qualified individual, analyzed the known or reasonably foreseeable hazards for the food to determine whether there are any hazards requiring a control, you may meet your requirement to determine whether there are any hazards requiring a control in a food by reviewing and assessing the hazard analysis conducted by that entity. You must document your review and assessment of that hazard analysis, including documenting that the hazard analysis was conducted by a qualified individual.

 

1.506 What foreign supplier verification and related activities must I conduct?

 

The determination of appropriate supplier verification activities must be based on the evaluation of the food and foreign supplier conducted under § 1.505.

 

(ii) Appropriate verification activities.  The following are appropriate supplier verification activities:

 

A) Onsite audits as specified in paragraph (e)(1)(i) of this section;

B) Sampling and testing of a food as specified in paragraph (e)(1)(ii) of this section;

C) Review of the foreign supplier's relevant food safety records as specified in paragraph (e)(1)(iii) of this section; and

D) Other appropriate supplier verification activities as specified in paragraph (e)(1)(iv) of this section.

 

If you are an importer, and you have records documenting the supplier verification activities you conducted to comply with the FSVP regulation, you can rely on those records as documentation of verification activities to comply with the supply-chain program requirements of subpart G.

 

Kind regards,

 

Tony

Edited by Tony-C, 15 February 2024 - 04:13 AM.

[kingstudruler1]

tony is spot on in my opinion.  it will be much clearer when you tke the class.   

 

In general it requires a HA of the ingredient, a RA of the supplier, and verification the hazard has been conrolled (if any)

 

the training manual: https://d1vy0qa05cdj...blicVersion.pdf

Edited by kingstudruler1, 15 February 2024 - 07:56 AM.

[QAKat]

If I am creating the program and being in charge of it I have to have a certified training? Or is being PCQI enough?

I just want to make it clear for my boss as I will be paying for the training because I have no experience in this but if it is mandatory I will be asking him to pay.

 

You guys are the best this is great help!

 

Thank you SO much