While US food and beverage processors will be taking steps to meet the requirements of the Food Safety Modernization Act (FSMA) for products they produce in the US, processors that import ingredients or products from foreign suppliers will be required to verify these suppliers meet the same criteria as their American counterparts under the new law, says Gary Nowacki, TraceGains CEO.

Nowacki, with more than 20 years of experience in food and related industry software, adds the two-year timer started ticking in January so importers need to start moving quickly. Section 301 of FSMA deals with foreign supplier verification and what’s involved in the process, which is not trivial.

Verification activities may include annual on-site inspections and checking the hazard analysis and risk-based preventive control plan of the foreign supplier, says Nowacki. In addition, verification activities may include monitoring shipment records, doing lot-by-lot certification of compliance and periodically testing and sampling shipments.

Each importer must perform risk-based foreign supplier verification activities for the purpose of verifying the imported food is as safe as food produced and sold within the US. Records must be maintained for a period of not less than two years and shall be made available promptly to the FDA upon request, adds Nowacki.

One of the major challenges to importers will be verifying foreign suppliers’ certificates of analysis (COAs), he adds. While it can be difficult enough to verify COAs from American suppliers accurately describe their products, verifying a COA from a Chinese supplier will be more difficult. The melamine issue a couple of years ago is a good example. While the COA listed protein, it certainly didn’t specify melamine as its source. Consequently, importers will be forced to do the lab work to verify foreign COAs.

The first best practice  processors need, according to Nowacki, is a firewall, “making sure that all foreign suppliers are in complete compliance with all requirements and food safety [practices]and rejecting shipments automatically if they’re not in compliance.”

Yesterday’s tools-paper receipts and COAs, spreadsheets and clipboards-can help, but they need to be integrated with modern software systems to provide the response time FDA requires.

For more information and an extended interview with Gary Nowacki, visit “Are you ready for Title III, FSMA 301?” on the FE Web site.