FOREIGN SUPPLIER
Foreign Supplier
Verification Program
mericans want assurances the food they ’ re consuming is safe . It ’ s estimated that 15 percent of the country ’ s food supply , including half of fresh fruit , 20 percent of vegetables , and up to 80 percent of seafood that ’ s consumed in this country is imported . Until the recent passage of the Food Safety Modernization Act ( FSMA ) — which was designed to overhaul the safety of the US food supply — there were few assurances that the food products being imported from foreign suppliers were safe . In addition to creating new standards for foreign suppliers , FSMA imposes new requirements on all domestic food companies as well .
FSMA was first enacted in January 2011 in response to the estimated 48 million Americans , or 1 in 6 , who are struck with foodborne illnesses each year . This leads to approximately 128,000 hospital stays and 3,000 deaths , according to data from the Centers for Disease Control and Prevention . That ’ s why strict food import requirements have been implemented by the Food and Drug Administration ( FDA ) to ensure significant food safety improvement on both domestic and imported food products .
FSMA has led to huge changes to the nation ’ s food security and safety . The FDA has shifted its focus from addressing foodborne illnesses from reaction to prevention .
One of the new requirements under FSMA is that , beginning on May 30 , 2017 ( with only some exceptions ), domestic importers of human and animal foods are required to develop and implement a Foreign Supplier Verification Program ( FSVP ), designed to verify that all food products entering the United States satisfy US safety standards .
Companies purchasing food from overseas must identify and evaluate known or foreseeable hazards for the foods they import to ensure that their suppliers are controlling for any biological , chemical and physical hazards which are reasonably likely to occur . Biological hazards include such things as parasites and disease-causing bacteria ; chemical hazards include things such as pesticides , drug residues , toxins , illegal food dyes or additives ; and physical hazards include things such as plastics , metal shavings or glass shards .
Any food processor or importer bringing food into the United States from overseas must follow specific processes to import these food products . In all cases , importers will be required to review and assess their suppliers ’ food safety programs to ensure that their suppliers are adequately controlling for known hazards . Depending upon the risk of the product at issue , these efforts might also involve doing third-party audits on the foreign supplier .
Such audits might include a walk-through of a food processing site , reviews of good manufacturing practices , an assessment of a supplier ’ s quality control programs , the foreign company ’ s recall plan and other things to ensure the foods that are reaching the United States are safe for consumers .
Although there isn ’ t an insurance product available to ensure that your FSVP will be compliant with the regulatory requirements , there are insurance products available to protect you in the event that you or a
BY : GWENYTH P . LUU , CLCS , VICE PRESIDENT OF PROPERTY & CASUALTY , JGS INSURANCE
supplier is forced to conduct a recall for product contamination or other reasons . JGS Insurance can help you assess your company ’ s relative food safety risk and design the product recall insurance policy that is right for your situation .
With that said , there are other ways to manage risk as well . The risk of any potential recall decreases dramatically if a company can achieve and also maintain compliance with the new FSVP regulations . JGS Insurance has partnered with industry experts , such as Food Industry Counsel LLC , the only legal and consulting firm in the world which advises the food industry exclusively . In addition to obtaining or enhancing your recall insurance coverage , take advantage of this opportunity to let the experts help you develop and implement a FSVP program that will withstand regulatory scrutiny . Adopting this strategy can help you reduce and then control your risk substantially .
Be sure to contact us to learn more about the services JGS Insurance and Food Industry Counsel LLC can provide . More information about JGS Insurance can be found at JGSInsurance . com . You can learn more about Food Industry Counsel LLC at foodindustrycounsel . com . +
As an insurance expert who focuses on the food and beverage industry , Gwenyth Luu has seen many unusual exposures and claims . That ’ s why she knows firsthand that it ’ s imperative for businesses to work with an industry-specialized insurance partner . Gwenyth has earned a certificate of completion in the HACCP System .
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