Tag Archives: supplier

FSMA, Food Safety Tech, FDA

FDA Releases New Guidance on Foreign Supplier Verification Program

By Food Safety Tech Staff
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FSMA, Food Safety Tech, FDA

With the first FSVP compliance rule just two weeks away, FDA has published a new guidance to help importers that are subject to the rule. “Guidance for Industry: Compliance with Providing an Acceptable Unique Facility Identifier for the Foreign Supplier Verification Programs Regulation” specifically provides information on the following:

  • How an organization identifies itself as an importer of food at entry into the United States
  • Requirement to provide a unique facility identifier that is acceptable by FDA
  • Information on what to do if the importer cannot obtain a Dun & Bradstreet Data Universal Numbering System number in time for the compliance date

FDA also identified the importers that fall under the May 30, 2017 compliance date. The foreign supplier would fall into one of the following categories:

  • The supplier will not be covered by the FSMA PC or Produce Safety rules
  • The supplier is subject to the Preventive Controls for Human Food rule and is not a small business, qualified facility or subject to the Pasteurized Milk Ordinance
  • The supplier is subject to CGMP requirements in the FSMA Preventive Controls for Animal Food rule and is not a small business or qualified facility

For importers that are unsure as to whether they are required to comply with the FSVP rule, the agency released a one-page chart, “Am I Subject to FSVP?”, along with a fact sheet about the final rule and the requirements under it, compliance dates and additional information.

5 Tips for Better Supplier Document Management

By Chelsey Davis
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What’s the best way to collect supplier documentation? You might read that sentence and think there is no best way…and you would probably be correct. There really is no best way to gather documentation other than sending a representative out to a supplier’s facility for an audit and document gathering. But we simply don’t have enough personnel to go that route.

Christopher Staub is a corporate raw materials coordinator with Advanced Food Products. Part of his job role is to ensure proper supplier documentation is in place for incoming raw materials. As a current TraceGains user, Staub offers his tips on how to help with supplier document management. 

What’s the best way to collect supplier documentation? You might read that sentence and think there is no best way…and you would probably be correct. There really is no best way to gather documentation other than sending a representative out to a supplier’s facility for an audit and document gathering. But we simply don’t have enough personnel to go that route.

Let me preface this by saying that one year ago, we had almost all of our supplier documentation in order, but it was already outdated, with some documents even as old as 2002. We needed updated information, and so began my journey of document collection…with plenty of pains along the way. For example, one of my least favorite tasks was explaining to a supplier the process of scanning a document to an email and then adding that scanned document as an attachment to an email. The best part? After this time-consuming process, I found out that the supplier could have simply attached the digital copy to begin with. This ultimately gave me quite a few headaches, but, to be honest, I think the actual aching came from me banging my head against the wall. Of course, this was a rare case. On some occasions, suppliers would actually have an efficient two-day turnaround on large quantities of documents. This was the perfect scenario! In the end, we managed to gather roughly 95 percent of all the documents my company requires, but as my example above illustrates, it was no easy feat.

With that being said, I would like to offer these tips to help you with your supplier document management.

1. Ensure Reference Numbers Are Consistent

Nothing is worse than getting responses from suppliers informing you that they cannot provide the documents you requested because they don’t know what materials for which the request was made. This is simply because your reference numbers aren’t matching theirs. To avoid this conundrum, make sure the ingredient name and part numbers that you have in your system match that of your suppliers. This will save you a lot of time and back-and-forth emails in the long run.

2. Approve and Store Documents Quickly

Typically, I try to approve and store new documents within a day of receiving them. If you are collecting a large amount of documents, you don’t want to get behind in the reviewing/approving process, especially when you have automatic emails going out to suppliers. You will not gain any bonus points if the supplier has to send you an email stating that the document in question was sent over a month ago simply because you did not have the document reviewed and stored correctly.

3. Accept Many Different Document Forms in Different Formats

Action Forms and questionnaires are great for collecting and extracting data, but will be rendered useless if a supplier does not/refuses to fill them out. It makes sense when you think about it… If I were a supplier, I wouldn’t want to fill out multiple questionnaires from hundreds of different purchasers–that would be exhausting. To help remedy this situation, I suggest setting up your systems to accept any supplier document in as many file formats as possible, so long as the document satisfies your requirements.

4. Keep Emails Clear and Concise

When you do need to email a supplier, make sure emails are as clear and as short as possible. With suppliers presumably receiving a significant amount of emails daily, it’s imperative that you get to the point as quickly as possible. Don’t make it the supplier’s job to sift through an agonizingly long email. Keep it simple.

5. Make It Personal

When all else fails, give the supplier a call. And while we do live in a digital age, sometimes a simple call will make all the difference and produce results. I’ll admit, I am a Millennial and would rather send a text or an email versus having to call someone. But the fact is, calling works.

Do you have additional tips regarding supplier relationships or document management? Leave a comment below and share. 

SCS Global's Sr. Technical Director and Auditor Heena Patel

What’s a Successful Food Safety Audit?

By Sangita Viswanathan
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SCS Global's Sr. Technical Director and Auditor Heena Patel

Audits and being prepared, and audit-ready are becoming increasingly important in the food safety world as the industry is moving to compliance with rules proposed under Food Safety Modernization Act. In this Q&A, from a webinar hosted bySafetyChain Software, and SCS Global Services, Heena Patel, SCS Global’s Senior Technical Director and Auditor answers some key questions about audits.

Q: What are the 5 top Best practices to follow for successful audits?

Heena Patel: As an auditor myself, I have conducted hundreds of audits. Auditors look for specific things and can make keen observations. They look for confidence, if the audit team on the site is well prepared for the audit or not. So be prepared for the audit. Be confident, follow the audit plan, have key staff present for the opening and closing meetings and for the facility walk through.

Don’t make the auditor wait for you to locate reports and records. Follow the audit plan; the plan is sent to the site ahead of time for a reason. It has details about the audit and what it would involve, and is a very good guideline that can be used to prepare for the audit by getting ready all the necessary reports and records.

Conduct mock internal audit to prepare for the final audit. Internal audits can help you prepare for any surprises. Use the information for the internal audit to answer questions during the actual audit.

Senior management must be prepared to show commitment and support for the food safety team. This matters a lot to the auditors.

And finally, feed your auditor well. It’s not a good idea to have a grumpy auditor.

Q: What are the biggest ‘No-Nos’ leading to deductions?

Patel: I would list the following items that lead to deductions:

  • Lack of management commitment and lack of team work;
  • Being unorganized and unprepared;
  • Not following and/ or not understanding code requirements; and
  • Not fully answering auditors’ questions.

Having incompetent team and incomplete documentation reveals the company not having the necessary training, or professionally trained personnel in-house. Having pre-requisite programs in place is huge in the audit checklist and this covers aspects such as sanitation practices, mock recalls, allergen management, training, testing, etc. We also look for business continuity plans, and management reviews. At SCS Global, we use a matrix with all this information to see what has been addressed well during the audit.

Q: What do auditors look for in demonstrating continuous improvement?

Patel: As an auditor, I love this aspect of an audit. Auditors don’t like to see that the program is not moving forward and is not getting the commitment and resources required from management. They must be focus on investing in employees with training and continuous education programs; and focus on upgrading structures and fixtures throughout the building as needed. Key performance indicators or KPIs must be developed that measure the performance of the food safety and quality program. These must be based on findings of the internal audit, external audit, or recalls etc. It’s also important to trend and evaluate this data during management meetings to see where the program stands and how it can be improved, as part of the continuous improvement program.

Q: How can companies best prepare for unannounced audits?

Patel: Unannounced audits are great from an auditor’s view point, as we can use this to see if the site is truly audit-ready at all times. Often with announced audits, we go in and notice that the floor has been swept well, there are no cobwebs anywhere, everything’s nicely arranged on the shelves etc. But you also realize that the mock recalls has been conducted the day before; the internal audit was conducted two days earlier. And this is not a good sign.

It’s important for food facilities to have a schedule in house in which records based on internal audits/ sanitation programs/ mock recalls etc. can be updated on a continuous basis. The actual audit should just be used to review and sign off on these records.

How can companies be audit ready at all times? By monitoring all programs continuously; keeping the facility clean at all times; and keeping the paperwork up to date at all times.

Q: How can automation/ technology facilitate audit readiness?

Patel: Many years ago when I used to audit food facilities, there were no automation systems in place. Auditors were using hard copies and paper checklists. Now, automation has made the entire process more efficient and communication friendly. Automation can help prepare audit plans, schedule tasks and assign food safety personnel to different parts of the program; have a centralized repository for records and data; work with Certified Bodies and suppliers who can all see information in one place; report non-conformances; put in place due dates for suppliers and auditors to either confirm or reject actions; have records on who conducted the audit, all non-conformances, all corrective actions etc. Having automation technology helps save on all the paper work involved in managing a food safety program and preparing for an audit.

To sum up, automation can:

  • Provide greater records efficacy;
  • Make it easier to communicate with your auditor when on-site and pre-/post audit;
  • Incorporate automated reminders to help food safety managers and auditors meet required deadlines; and
  • Save time preparing for your audit by automating record keeping.

Get more insights into the auditor’s point of view as Heena Patel answers more questions on this topic. Click here to access the recorded webinar