Food Safety

FSMA Warning to Importers

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While attending the Fancy Food Show in San Francisco a few weeks ago, I couldn’t help but notice some blank stares when I asked various company representatives about being FSMA compliant.  Now granted, many of these exhibitors were from different countries around the globe… but most spoke excellent English…so I don’t think it was a matter of not understanding my question.  They just didn’t know what I was referring to when I asked about specific food safety issues.  I thought at first it was just a few companies…but it happened several times.

And in fairness, there were many companies that did understand the importance of being FSMA compliant and knew what I was talking about and said they already had a FSVP (Foreign Supplier Verification Program) in place.

But here’s the thing.  Up until now the FDA has been fairly lenient and many importers have managed to fly beneath the radar.  However, this year, in 2020, the FDA is prepared and ready to take a much tougher stance.  Lack of knowledge in this area could prove very costly for your company.  Ignorance is not an acceptable excuse with the FDA.

As a foreign food manufacturer supplying product to the USA you must be FSMA compliant.  As an importer, you are required to have a procedure in place that enables you to approve the food safety system of any of your foreign suppliers.  In other words, it means that importers are now required to perform certain risk-based activities to verify that the food they are importing has been produced to meet U.S. safety standards.  Importers must create, follow and maintain a FSVP for every food brought into the U.S.A. and the foreign supplier of that food.  If you have several suppliers of the same product you need a separate FSVP for each supplier.

Be aware that the FDA may detain and refuse entry of your product or place imported food products on import alerts to inform FDA field staff that they may detain (initiate a refusal of admission) future shipments of food with out physical examination.

Note that there are certain foods that are exempt from the FSVP Rule as follows:

  • Fish and fishery products imported from a foreign supplier that is required to comply with and is in compliance with FDA’s Hazard Analysis and Critical Control Point (HACCP) regulations or those products as well as for certain raw materials or other ingredients for use in processing fish or fishery products in compliance with HACCP.
  • Juice products that are imported under the same conditions as above.
  • Food for research or evaluation
  • Food for personal consumption
  • Alcoholic beverages and certain raw materials and ingredients that are imported for use in alcoholic beverages
  • Food that is imported for processing and future export
  • Low acid canned foods, such as canned vegetables, but only with respect to microbiological hazards
  • Certain meat, poultry and egg products
  • Food that is transshipped (meaning it stops here in the U.S. enroute to another country)
  • S. Food that is exported and returned without further manufacturing or processing in a foreign country.

Noon International takes food safety very seriously and we are proud to offer an exciting NEW course created by Nancy Scharlach, Chief Technical Director, FSMA International.  Noon International has been working with Nancy for the past several months and her latest course, How to Convert Your HACCP Plans to HARPC to Meet FSMA Requirements is now available!

Many of you may already know Nancy.  She has been involved actively in food safety for more than 24 years and you may have attended one of her podcasts or classes in the area of food safety in her home state of Denver, Colorado.  Nancy may have even visited your plant and worked with you to reach FSMA compliance!  She’s a lead instructor for FSPCA FSMA Foreign Supply Verification Program and FSPCA FSMA Preventive Controls for Human Foods. But perhaps her most important qualification is her passion for human food safety.

Nancy has lectured and worked with more than 1000 companies in 25 countries worldwide and what she discovered prompted her to make this NEW COURSE available ONLINE.  She found that a great majority of foreign frozen food processors (and domestic, as well) are NOT FSMA compliant – in fact, far from it.  The online course she has created is perfect for any and all plants producing human food and allows those of you in foreign countries to study with her.

YES!  PLEASE SEND ME MORE INFORMATION ON NANCY’S FOOD SAFETY COURSE

In Nancy’s own words:

The problem is that many processors still believe that having HACCP in place and passing a Third-Party Audit is enough.  Heres the truth: While Third-Party Audits and HACCP are still priorities, these practices alone dont meet the new FSMA Food Safety Requirements and there is a good chance your product will not be allowed into the United States.

Please watch this short video from Nancy – she explains everything!

This online study course is excellent for all members of your food safety team as well as owners, managers and importers.  The material can be referred to time and time again and it’s a great training tool for all plant personnel.

Nancy shows you how to develop your plan and put it into practice is a step-by-step process that is easy to understand and implement.

YES!  PLEASE SEND ME MORE INFORMATION ON NANCY’S FOOD SAFETY COURSE

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