The Foreign Supplier Verification Program (FSVP) is yet another legal regulation that applies to food importers. You may already be making significant efforts to comply with the many safety regulations. And the implementation of yet another compliance program may appear to be an overwhelming prospect. However, FSVP is a prerequisite you cannot omit under any circumstances.
The FDA prohibits your ability to rely on an appropriate verification activity conducted by your foreign supplier’s self-audit. However, the good news is that the FDA will accept third-party analyses, evaluations, and activities for meeting FSVP requirements. The only requirement is to review and evaluate the documentation corresponding to these activities.
Therefore, if you do not have local auditing staff based in the country where your company manufactures its products, hiring a professional third-party Food Safety Auditors/ Organic label consulting firm may be a more cost-effective solution for your company to comply with regulations.
You could hire a third party for the following:
The Food and Drug Administration (FDA) has not yet established any mandatory FDA FSVP training programs, certifications, or other requirements for qualifying third parties. Therefore, even though you have some leeway in selecting a third party, it is essential to thoroughly investigate their experience before employing them.
A significant number of importers employ the services of a third-party HACCP Consultant to conduct pre-audits on both potential and existing suppliers. A GMP pre-audit is carried out before the scheduled date of an official FDA inspection and, for the most part, follows the same pattern as an official audit.
The FDA maintains a flexible policy regarding the kinds of audits that importers are permitted to use to satisfy the FDA’s requirements for supplier verification. In general, the audit is required to:
Be carried out by an auditor qualified to carry out the audit based on their education, Food safety internal auditor training, and experience in the relevant fields.
During the audit, an auditor should be able to spot potential hazards and document any non-compliance. After the audit, many auditors will provide your supplier with a corrective action plan to address violations.
In most cases, you will be required to re-audit your suppliers after some time to determine whether they have implemented the requested corrective actions. It is highly unusual for a supplier to independently follow up on corrective actions without some oversight from the supplier’s customer.
A credible third-party auditing company ought to be able to devise a strategy for timely follow-up with your supplier to evaluate the supplier’s implementation of corrective actions and should be able to do so. It is possible that providing your supplier with a GMP audit checklist will assist your supplier in better understanding the requirements that they are expected to meet.