According to one proposed food safety rule issued by the U.S. Food and Drug Administration, importers would be responsible for verifying that their foreign suppliers are implementing prevention-oriented food safety practices and are reaching the same level of food safety as domestic processors. In another, FDA proposes ways to strengthen the quality, objectivity and transparency of foreign food safety audits, which importers rely on to help manage the safety of their global supply chains.

How these two rules, issued under the Food Safety Modernization Act, will work once fully implemented is raising questions for dairy facilities.

• Will the Foreign Supplier Verification requirements that apply to foreign facilities be mimicked in domestic requirements by operation of international law?
• Will third-party auditors become de facto FDA inspectors as a result of the mandatory reporting requirements imposed on them by their accreditation?
• FDA’s proposed rule strongly encourages companies to visit their suppliers’ locations on an annual basis. Does that mean a facility that supplies 200 companies will have 200 pairs of boots marching through it every year?

To address these and other questions about the two proposed rules, IDFA is hosting a webinar titled “Food Safety Modernization Act: Foreign Supplier Verification and Third-Party Accreditation” on October 24, 1:30-3:00 p.m. Eastern time. Webinar participants will hear from food safety expert Joe Levitt, a partner with Hogan Lovells, US LLP and former director of FDA’s Center for Food Safety and Applied Nutrition (CFSAN). He will discuss what is specifically included in the proposed rules, including key effective dates and the implementation timeline for compliance.

“While the new requirements on foreign supplier verification and the accreditation of third-party auditors are intended to further protect the safety of food imported into the United States, it is not yet clear how these rules will effect domestic suppliers,” said Clay Detlefsen, IDFA vice president of regulatory affairs. “IDFA will continue to engage with FDA throughout the FSMA implementation process to ensure that the final outcome is reasonable for our member companies.”

Knowing that FSMA will dramatically increase FDA’s access to a dairy foods company’s records during onsite inspections, IDFA has created another webinar that will review the steps a facility needs to take now to get its recordkeeping into a FSMA-ready state. The webinar, “Food Safety Modernization Act: Good Recordkeeping Practices,” will be held November 19, 1:30-3:00 p.m. Eastern. Also presented by Levitt, the webinar will share daily practices for successful recordkeeping and provide key principles for creating records of particular significance under FSMA.

For more information about FSMA, contact Clay Detlefsen, IDFA vice president of regulatory affairs, at cdetlefsen@idfa.org.

For more information about the webinar, contact Maria Velasco, IDFA assistant, meetings and educational services, at mvelasco@idfa.org.