the requirements of the rule; otherwise, there will be repeat failures on the part of
importers. Kudos to FDA for making it clear that the initial phase of implementation
of the rule is going to be an opportunity for importers to crawl before walking. n
Dr. Ramakrishnan Nara is a technical adviser/consultant for the food, pharma, and dietary supplements industries. He can be contacted at email@example.com.
happened in 2008–2009. The need to
enhance traceability and transparency in
the food supply chain is overdue.
The FSVP rule requires importers to ensure their products are safe
and ensure the integrity of the supply
chain. The global food supply chain is
complex, loaded with several unknown
factors that an importer in the U.S cannot easily detect and control. While the
regulatory requirements to ensure the
integrity of the supply chain are clear,
importers do not have effective tools
to achieve these objectives. Blockchain
technology is the best solution for this.
Blockchain is nothing but a chain of
blocks (records) arranged in a chronological order. Therefore, the possibility
of altering records is greatly reduced.
Currently, the technology is in its
infancy particularly as it applies to food
safety. Nevertheless, it offers enormous
potential for improved product traceability in the supply chain. Importers
will be able to trace the full history of
the products they are importing. It will
be much easier to protect the integrity
of the food supply chain and consequently prevent major foodborne illness
as this new technology matures.
Challenges Ahead for FSVP
It is going to be a tough task for at
least the very small importers to comply
with the requirements within the specified timeline, knowing their limited
technical capabilities and financial constraints. Implementation of the requirements of the FSVP rule is not a simple
task. It requires a good understanding
of the hazards associated with food
products and their control measures.
Although FDA has published guidance
documents, importers are not yet fully
prepared. The other major hurdle for
very small importers is maintaining
proper documentation and records. The
food importer community needs to be
more disciplined in this respect.
On the other hand, FDA may also
face some challenges in enforcing the
FSVP rule. The agency has to make sure
the importer community understands