FSMA-FDA Registration for R&D

My facilities make food contact packaging. Our Corporate HQ does product testing and R&D and receives food from our customers in order to test the packaging. If there is a surplus, we occasionally give away the extra food, still sealed, to employees. In the past we have registered as an FDA facility due to this, on the basis that we're holding food that is consumed by the public. We fall under the exemption for supplier verification as an R&D facility except that we give the extra food away on occasion, maybe a few times per year. Has anyone else experienced a similar issue or gotten an exemption?

These days you're company may want to think twice before continuing this practice. Is the food sent to you're company to test the packaging safe? Is it ready to eat and if so has it been tested for pathogens? Any possibility of allergen cross-contact? If you don't have this information and one of your fellow employees become sick there could be liability issues.

On the face of it I agree with Esquef...but in order to make an educated judgement we would need to know what the food is (high, medium or low risk) and how safe it is when it comes to you (manufactured, stored, delivered and verified 100% safe or not).

Regards,

Simon

My best advice is to discontinue the practice due to liability.  I worked in a place where the leftover breading was donated to a pig farm and the pigs got sick.The owner try to get compensation from us for his loss of business.  I hate to waste food but with the times we are living in is not worth the aggravation.  Because of this incident, we had to discontinue the donation or giving away food due to left over, trials, and test runs to local Charities and Farms within the surrounding areas.

I hope this helps,

Arquelio