Two proposed FSMA rules, Risk-Based Preventative Controls for Human Food and the Foreign Supplier Verification Program (FSVP), place high expectations on companies surrounding their supplier controls.
During a recent Tech Talk, “Tackling FSMA Compliance”, Melanie Neumann, executive vice president and CFO of The Acheson Group, offered advice on how companies can use technology to execute on the challenges they will face under FSMA.
Globalization. “We as an industry are sourcing more ingredients than ever before—more by volume, more by way of uniqueness, and more by way of more countries,” says Neumann. “We have more companies that are playing in the global supply chain, and arguably, it’s a growing spider web versus a chain.”
Importer of Record. These days, companies have to keep track of more information than ever. “That’s where technology can come into play,” says Neumann. “We have other challenges like trying to understand who really is the importer of record, because there’s some regulatory vagueness with respect to that definition.” Variations, such as how the Bioterrism Act and the FSVP define importer of record, can also cause confusion. “We need to take a deep dive within our organizations and ask, ‘Am I the importer of record? Do I need to comply with foreign supplier verification?’”
Foreign supplier awareness. Some companies can’t name all the foreign suppliers present in their supply chain, and this is compounded by the reality that some foreign suppliers doesn’t understand FSMA. “Some foreign suppliers haven’t heard of FSMA, and we have a very short period of time to compliance to get them ready if you still want to source from them,” says Neumann. “Technology can help us track back and keep record of the supply chain.”
Stay on top of risk instead of letting risk catch up with you
Keeping track of mountains of information while controlling risks within a paper-based environment is quickly becoming obsolete and potentially dangerous. Having the electronic documentation will help prove compliance with requirements. “Gone are the days where we can manage all these requirements in a filing cabinet. The technological solutions out there can help you put everything in an electronic format that is searchable and at your fingertips in minutes. By regulation, you’ll need the information within hours,” says Neumann. “These systems are building in mechanisms to auto-alert you, so if something looks like it is becoming out of spec or compliance, it will raise an electronic hand. It also helps you keep and meet the record keeping compliance requirement from both a foreign and domestic supplier management perspective.”
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