do to help them. In my current role, we are focused on traveling to our suppliers’
locations, having discussions with the factory professionals about practices and procedures, walking the factory floor, concluding the assessment with a closing discussion, and then enjoying a meal together while sharing our professional and personal
experiences. Again, the personal side of business is important. I want my suppliers to
care about our company, customers, and our customers’ consumers.
The key to understanding any process is to deconstruct it and look at the parts
individually while keeping in mind how they will all fit back together and function.
Below is a list of the requirements of an FSVP and a summary of how I recommend
addressing each one:
Use a qualified individual to develop an FSVP and perform FSVP activities: At a minimum, your designate should successfully complete FSVP training. Ms. Neff successfully completed a Preventive Controls-Qualified Individual (PCQI) training and
an FSVP prior to setting up the structure, and I successfully completed the PCQI,
PCQI Instructor, and FSVP courses.
Perform a Hazard Analysis that includes identifying known or reasonably foreseeable
hazards associated with each type of food and determining whether they require a control:
The intent of this item in the final rule is to ensure the IOR understands the risks
associated with the ingredient they are bringing into the country. We prioritized
the Hazard Analysis by product volume and lethality step control (supplier or customer), and performed an annual risk assessment focusing on preventive controls for
biological, chemical, and physical hazards at our high-volume/high-risk suppliers.
Evaluate risks posed by the food and the performance of the foreign supplier: This requirement is ingredient-shipment specific. To quote President Ronald Reagan: “Trust but
verify.” Ask for supporting documents, go to the supplier’s location, ask pointed
questions, and gain a detailed understanding of your supplier’s processes and procedures. We evaluate the process flowchart, Hazard Analysis document for the
ingredient(s), validation studies for the lethality steps (if identified as a Critical Control Point), food safety plan, certificates of analysis per shipment, and supporting
documents such as pesticide residue lab results.
Conduct appropriate supplier verification activities to provide assurance that the hazards
requiring a control in the food you import have been significantly minimized or prevented:
This step is also focused on the validation of procedures and verification that the
procedures are followed. Low-risk supplier verification activities may include reviewing updated third-party audits, conducting supplier meetings at trade shows, and
reviewing corrective actions identified in the third-party audit and/or corrective
actions for issues identified by our customers. Spending extra time on corrective actions is very important because it provides an insight into the management commitment of the supplier. I will address this further later.
Reevaluate the food and foreign supplier every 3 years: No matter the size and/or
Keys to Evaluating a Potential
budget of your operation, you must request an updated Hazard Analysis and Criti-
cal Control Points (HACCP)/Hazard Analysis and Risk-Based Preventive Controls
(HARPC) plan and risk assessment from your supply chain. We perform annual risk
assessments at our high-volume suppliers. The benefits are twofold: First, we gain
a visual perspective of process improvements from the previous year. Second, we
strengthen the business-personal relationships with the management team by sharing
meals and conversation. Document management systems come in handy when re-
questing the updated HACCP/HARPC
risk assessments on a 3-year schedule.
A significant number of further
processors retain their own in-house
auditors or contract with third-party
certification bodies. A recommendation
is to conduct a targeted risk assessment
for your customers to determine whether they want to invest the resources to
move forward with the new ingredient
on-boarding process. The purchasing,
R&D, regulatory compliance, and food
safety folks appreciate a heads-up, so
to speak. Nobody wants to waste the
substantial cost of sending an auditor to
a location that will fail because of major
deficiencies in their food safety plan.
In most cases, a certification body
has audited the potential site, and a
good idea is to carefully review the
report. Another key component is a pre-site assessment, what some refer to as a
desk audit. The HACCP flowchart for
a review prior to each product is a standard item to have in hand when you are
performing a desk audit and during the
walk-through at the supplier location.
It is your guide to what preventive controls have been identified as potential
hazards by the factory management.
I have found that internal audits
provide an insight into how a supplier
manages their business. The internal
audit identifies issues in the factory, and
the corrective action completion data
indicate the management commitment.
Internal audits are a key component
to an organization’s ability to identify
potential hazards, conditions that can
cause disruptions in throughput, and
situations that can create employee
safety risk. A supplier that has a robust
internal auditing program can prevent
issues that may contribute to a system
failure. The critical component to an
internal auditing program is implementing an effective corrective action and
then verifying the corrective action
solved the issue.
FOREIGN SUPPLIER VERIFICATION
“Your suppliers need to know you,
understand what your concerns are, and
what you can do to help them.”