On July 26, 2013, the U.S. Food and Drug Administration (“FDA”) proposed regulations for the Foreign Supplier Verification Program (“FSVP”) as mandated by the Food Safety Modernization Act (“FSMA”) of 2010. In this video, Benjamin England, Founder and CEO of FDAImports.com, discusses some of the implications of FSVP for members of the seafood and juice HACCP community.
Stay tuned – we’ll be posting more videos and blogs explaining FSVP and its implications in the coming weeks. To learn more about the impact these regulations will have on your business, or to work with FDAImports.com on writing and submitting comments on the proposed FSVP rules, contact us today.
The second important group are the seafood companies — those companies that either manufacture and export or that import. Now I know that most companies are saying, “yeah, but we’re exempt, we’re exempt, it doesn’t really matter.” The fact of the matter is, you’re already not exempt; FDA already issued a regulation when they issued HARPC and the Standards for Produce Safety, they also issued a food GMP rule that already affects HACCP. And you can see our video on that on HARPC.com; please go have a look at it. But this FSVP program is going to also create a circumstance where FDA will not allow the seafood importers to continue to operate the way they have been.
Now if you’re familiar with seafood HACCP, you know that there’s an importer verification step. That step is far less rigorous, far less difficult to comply with, than the Foreign Supplier Verification Program. From FDA’s perspective, seafood is one of the high-risk foods. And even though it’s true that the Foreign Supplier Verification Program does not cover seafood, and HACCP does, what will happen is that FDA will modify HACCP in order to cause the requirements to raise up, and be equal, more connected, more directly related to the Foreign Supplier Verification Program.
Now people say, “Well how can they do that? They weren’t given the authority, seafood companies are exempt from FSVP as long as you comply with HACCP,” and that’s all true. Well, the way they’re going to do it is, they’re going to just modify the HACCP regs. “Well, how can they do that, if they don’t have the authority under FSVP to apply these same kinds of standards?” Well, my response is: in my view, they didn’t have the authority to do HACCP. And that didn’t bother them the first time, it won’t bother them the second time. So, you should watch out the seafood industry will, without doubt, be affected by the Foreign Supplier Verification Program, or the requirements, the criteria, that’s built into that system. One of the next steps FDA will take will be to change HACCP to cover that.
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© 2013 FDAImports.com.