FSVP modified requirements
Foods found not to be in compliance risk costly detention and in some cases disposal at the US border. Ensuring that food safety standards and procedures are well vetted and well documented will help firms navigate these challenging rules with greater ease. Any food manufacturer has access to the resources of EAS Consulting Group. EAS can provide first-hand knowledge of US FDA requirements to help verify foreign suppliers are meeting US requirements. *Charles M Breen became an Independent Advisor, Food Safety Modernization Act and came to EAS Consulting Group after a distinguished career at the FDA working in areas such as HACCP and LACF and BSE prohibited materials. Mr Breen worked with the industry on compliance issues related to the Bioterrorism Act of 2003 and led field and HQ professionals in developing and implementing surveillance and compliance programs, and initial FSMA training implementation. His attention to detail has garnered him an FDA Award of Merit, Outstanding Achievement and five Commissioner Special Citations. EAS Consulting Group specialises in Food and Drug Administration (FDA) regulatory matters. The company’s prime focus is to assist domestic and foreign food, dietary supplement, pharmaceutical, medical device, tobacco and cosmetic firms to comply with applicable laws and regulations.
www.foodprocessing.com.au
May/June 2017
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PROCESSING
Some importing firms will find their requirements under FSVP are modified. There are many examples, some of which are: • When a US facility’s manufacturing process controls the hazards of the imported food, then the US facility is considered in compliance with most of the FSVP rule. • When a food being imported does not have any identified hazards requiring control, then the US facility is considered to be in compliance with most of the FSVP rule. • If the US facility has implemented a supply-chain program for the food in compliance with either Preventative Controls for Human Food (PCHF) or Preventative Controls for Animal Food (PCAF) requirements, the US facility is considered to be in compliance with most of the FSVP rule. There exemptions are provided to some very small suppliers, those defined as less than US$1 million in sales of human food a year, or less than US$2.5 million in sales of animal food per year. The FSVP Rule is a major element of USFDA’s newest FSMA regulations. It requires US importers to make a thorough assessment of food safety at foreign food manufacturers. Those foreign manufacturers may need to revise some of their processes and/or documentation practices to ensure compliance with FDA’s import regulations. US importers are required to know and verify that imported food is in compliance with FDA requirements.