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Current FDA Requirements & the New Food Safety Modernization Act Presented by Registrar Corp February 23 rd , 2016

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Page 1: Current FDA Requirements & the New Food Safety ...Not complying with U.S. Food and Drug ... Pre-1906: No regulation Upton Sinclair’s The Jungle Pure Food and Drug Act of 1906. Creation

Current FDA Requirements

& the New Food Safety

Modernization Act

Presented by Registrar Corp

February 23rd, 2016

Page 2: Current FDA Requirements & the New Food Safety ...Not complying with U.S. Food and Drug ... Pre-1906: No regulation Upton Sinclair’s The Jungle Pure Food and Drug Act of 1906. Creation

Thailand & the U.S. – Why export?

A short history of the FDA

Review of current FDA requirements

The Food Safety Modernization Act (FSMA)

FDA Import Refusals and Detention Without Physical

Examination (DWPE)

FDA Inspections

Summary and Q&A

Seminar Overview

2

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2/23/2016

Why Export to the U.S.?

Thai – U.S. Relations & Trade

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Why Export to the U.S.?

The United States is the world's largest economy and the

largest exporter and importer of goods and services

GDP of $16.77 trillion

4

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In 2015, the U.S. imported an estimated…

Seafood: $17.2 billion

Fruits & Frozen Juices: $14.2 billion

Vegetables: $9.9 billion

Meat products: $11.9

Bakery products: $8.7 billion

And much more…

Total U.S.-imported food: $116.8 billion

5

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The U.S. Market

6

317 million consumers

Large variety of ethnicities, ages, climates, etc.

Diversity of tastes and incomes provides a market for

any product

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Multiple Distribution Opportunities

7

Large Grocery Stores

E-Commerce

Specialty Stores

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U.S. – Thai Relationships

8

Imported Thai goods totaled $26.2 billion in 2013

Thailand ranks as the U.S.’s 19th largest supplier of

goods imported in 2013

Trans-Pacific Partnership – possible ratification

Page 9: Current FDA Requirements & the New Food Safety ...Not complying with U.S. Food and Drug ... Pre-1906: No regulation Upton Sinclair’s The Jungle Pure Food and Drug Act of 1906. Creation

Before you export…

9

The U.S. is a regulated market, so many rules apply

Not complying with U.S. Food and Drug

Administration regulations has negative consequences

Prepare in advance to avoid costly mistakes

Page 10: Current FDA Requirements & the New Food Safety ...Not complying with U.S. Food and Drug ... Pre-1906: No regulation Upton Sinclair’s The Jungle Pure Food and Drug Act of 1906. Creation

2/23/2016

The U.S. Food and Drug

Administration

A Short History

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Beginnings - 1906

11

Pre-1906: No regulation

Upton Sinclair’s The Jungle

Pure Food and Drug Act of

1906

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Creation of the FDA - 1938

12

President Franklin

Delano Roosevelt signs

the Food, Drug, and

Cosmetic Act in 1938

after over 100 people die

from taking Elixir

Sulfanilamide

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The Modern Age

13

In the 1960s, the Pillsbury

Corporation developed the

first Hazard Analysis and

Critical Control Point

system for NASA

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Toward the Future: FSMA

14

President Obama signed the Food Safety

Modernization Act into law on January 4th, 2011

FDA calls it the “most sweeping reform of our food

safety laws in more than 70 years”

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FDA’s Current Structure

15

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2/23/2016

Current FDA Regulation

A Brief Review

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The Bioterrorism Act of 2002

17

September 11th, 2001

Requires food facilities to:

Register with the FDA

Designate a U.S. agent for

communication

Give prior notice on food

shipments

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Food Facility Registration

18

Food facilities engaged in

“manufacturing, processing,

packaging, or holding of

food” must register with the

FDA

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Food Facility Registration

• Thailand – 1,530

• Myanmar – 11

• Cambodia – 76

• Vietnam – 1,536

• Laos - 33

• China – 26,743

• Indonesia – 2,598

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U.S. Agent

20

Foreign food facilities must also designate a U.S. agent

as a point of contact for FDA

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Prior Notice

21

Foreign food facilities are required to give FDA “prior

notice” on shipments to the US

Prior Notice must be filed before a shipment arrives

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Food Labeling

22

• A top reason product is detained: Incorrect labeling, unapproved ingredients, prohibited health claims

• Common errors in trying to avoid problems:

• Copy other wrong labels

• Only follow part of the regulations

• Nutrition Facts chart formatting is critical and will soon change

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Requirements for Low-Acid/Acidified

Canned Foods (LACF)

23

• Low-Acid, Acidified, Thermally Processed Foods

• Typically produced in Cans, Bottles, Jars, or Tetra-Paks

• Food Canning Establishment (“FCE”)

• Registration required

• Process Filings (Submission Identifies or “SID”) for each product, each size

• Important factors are pH and Water Activity

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HACCP

24

• Focuses on the prevention of hazards

• Can be applied throughout the food chain

• “From farm to table.”

• Currently required for

• Seafood (21 CFR§123)

• Juice (21 CFR§ 120)

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Current Good Manufacturing Practices

(cGMPS)

25

• Guidelines and conditions which must be met by every food facility to ensure production of safe and wholesome foods.

• GMPs required for all food and beverages are found in 21 CFR §110

• GMPs required for dietary supplements are found in 21 CFR §111

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cGMP – 21 CFR § 110

GMP requirements include:

Sanitation

Employee hygiene and hygienic practices

Equipment construction, maintenance and calibration

Pest Control

Facility construction

Water quality

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FSMA Changes to Current FDA

Requirements

27

Registration

Food facilities must renew their registration every

even-numbered year (2016, 2018, 2020, etc.)

Must include the U.S. agent email address on their

registration renewal

Prior Notice

Food facilities must state if a food offered for import

to the U.S. was refused entry at the port of another

country

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LACF System Changes

• In October 2015 FDA changed a number of features

in the LACF system. Major changes include:

• New access roles determine who can file and see

filings, and who can have access in general.

• New forms have replaced forms used for the past

30+ years

• New features within the actual submission process.

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2/23/2016

Food Safety

Modernization Act

(FSMA)

What You Need to Know

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Motivators for FSMA: Facts

30

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High Profile Cases

Imports in the spotlight over past decade:

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High Profile Cases

High profile food scandals originating in the U.S.

as well:

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Imports on the Rise

33

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FSMA Places Burden on Importers

and Foreign Manufacturers

•Increase in exports to the U.S.; too many ports; not enough

FDA inspectors.

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Progress with the FSMA

35

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Progress with the FSMA

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FSMA: Four Areas

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FSMA: Who Can Be a “Qualified Individual”?

• Must have education, training, or experience (or

combination thereof) necessary to perform the activity

• Must be able to read and understand the language of

any records reviewed in performing an activity

Manufacturers/Importer must use a Qualified Individual

for required FMSA tasks

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FSMA: Preventive Control (PC) Rule

Food Safety Plan

• Hazard analysis

• Preventive controls

• Supply-chain program

• Recall plan

• Procedures for monitoring

• Corrective action procedures

• Verification procedures

• Recordkeeping

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FSMA: Preventive Control (PC) Rule

Food Safety Plan

• Food plan based on “Hazard Analysis and Risk-

based Preventive Controls” (HARPC)

• Looks at which foods offer which hazards and

evaluates risks

• HACCP vs. HARPC

• Must be written by a qualified individual

40

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FSMA: PC Rule

Who Must Comply?

• Facilities that manufacture, process, pack or hold

human food

• In general, facilities required to register with FDA

under sec. 415 of the FD&C Act

• Not farms or retail food establishments

• Applies to domestic and imported food

• Some exemptions and modified requirements apply

41

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FSMA: PC Rule

Who’s exempt?

• Activities subject to Hazard Analysis & Critical

Control Points (HACCP) regulations (i.e., seafood

and juice)

• Manufacturing, processing, packing, and holding

of dietary supplements

• Alcoholic beverages at certain facilities

• Activities subject to low-acid canned food

regulations (microbiological hazards only)

42

Page 43: Current FDA Requirements & the New Food Safety ...Not complying with U.S. Food and Drug ... Pre-1906: No regulation Upton Sinclair’s The Jungle Pure Food and Drug Act of 1906. Creation

• Very small businesses• Less than $1 million in annual food sales

• Three years: September 17th, 2018

• Small businesses• Businesses with fewer than 500 full-time employees

• Two years: September 17th, 2017

• All other businesses• One year: September 17, 2016

PC Rule: Compliance Dates for Businesses

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Page 44: Current FDA Requirements & the New Food Safety ...Not complying with U.S. Food and Drug ... Pre-1906: No regulation Upton Sinclair’s The Jungle Pure Food and Drug Act of 1906. Creation

FSMA: Foreign Supplier Verification Program (FSVP)

• Requires importers to share responsibility for

ensuring safety of imported food

• Risk-based (according to types of hazards,

importers, and suppliers)

• Flexibility in meeting requirements (assessing

activities conducted by others)

• Alignment with PC supply-chain provisions

44

Page 45: Current FDA Requirements & the New Food Safety ...Not complying with U.S. Food and Drug ... Pre-1906: No regulation Upton Sinclair’s The Jungle Pure Food and Drug Act of 1906. Creation

Purpose of FSVP

•Importers must provide adequate assurances

that:

• Foreign suppliers produce food using processes

and procedures providing same level of public

health protection as FSMA preventive controls or

produce safety provisions

-and-

• Food is not adulterated or misbranded (as to

allergen labeling)

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FSVP: How’s it Work?

General Requirements of the FSVP

A “Qualified Person” Must Perform the Following:

• Hazard Analysis

• Supplier Verification Activities (including

compliance status review of foods and suppliers)

• Corrective Actions

• Periodic Reassessment of FSVP

• Importer Identification at Entry

• Record-keeping

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FSVP: Hazard Analysis

• Evaluate known or reasonably

foreseeable hazards to determine if

they require a control

• Biological, chemical (including

radiological), and physical hazards

• Naturally occurring, unintentionally

introduced, or intentionally

introduced for economic gain

• May assess another entity’s hazard

analysis

47

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FSVP: Approved Suppliers

To approve suppliers and determine appropriate

supplier verification activities

Importers must consider:

• Risk posed by the food (hazard analysis)

• Entities controlling hazards or verifying control

• Supplier characteristics (procedures and practices;

FDA compliance history, including Warning Letters,

Import Alerts, etc.)

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FSVP: Verification Activities

• Onsite audits (default for serious hazards)

• Sampling and testing

• Review of relevant food safety records, including

monitoring a supplier for FDA Warning Letters or Import

Alerts

49

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FSVP: Supplier Verification Activities

• May rely on another entity’s determination or

performance of appropriate verification activities (e.g.,

farm audits conducted by produce distributor, BRC

audit, etc.)

• Must review and assess results of verification activities

(importer’s own or others on which it relies)

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FSVP: Supplier Verification Activities

Modified Requirements

• If the food cannot be consumed without application of

control (e.g., coffee beans)…

or

• The hazard is controlled by importer’s customer or

subsequent entity in US distribution…

• The importer must include a disclosure statement with the

food and/or obtain written assurance from the subsequent

entity in the supply-chain that they will control the hazard

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FSVP: Corrective Actions

52

Page 53: Current FDA Requirements & the New Food Safety ...Not complying with U.S. Food and Drug ... Pre-1906: No regulation Upton Sinclair’s The Jungle Pure Food and Drug Act of 1906. Creation

FSVP: New DUNS Requirement?

• Importers will have to include:

DUNS number?

Email address at time of

entry

53

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FSVP: Recordkeeping

• Importers must document their activities related to:

Approving suppliers

Supplier verification activities

Corrective actions

• Importers must retain these

records for at least two years

54

Page 55: Current FDA Requirements & the New Food Safety ...Not complying with U.S. Food and Drug ... Pre-1906: No regulation Upton Sinclair’s The Jungle Pure Food and Drug Act of 1906. Creation

FSVP: Who Must Comply?

• “Importer”: defined as

owner or consignee

• If there is no US owner or

consignee, the “Importer” is the

U.S. agent or representative of

the foreign owner or consignee,

as confirmed in a signed

statement of consent

55

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FSVP: Who’s Exempt?

• Firms subject to juice or seafood HACCP regulations

• Food for research or evaluation

• Food for personal consumption

• Alcoholic beverages and ingredients (when importer uses them to

make an alcoholic beverage)

• Food transshipped through U.S.

• Food imported for processing and export

• “U.S. food returned”

• Meat, poultry, and egg products subject to USDA regulation at

time of importation

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FSVP: Who’s Exempt?

Very Small Importer (VSI)

• Less than $1 million/yr. in human food sales

• Less than $2.5 million/yr. in animal food sales

Food from certain small suppliers

• Qualified facility (same $ as VSI)

• Produce from certain small suppliers that are not

covered farms

• Shell egg producers with < 3,000 laying hens

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VSI and Importers of Foods from Small Suppliers

• Annually document eligibility

• Verification: Written assurances from suppliers

• Additional requirements for food from small suppliers:

Evaluate supplier compliance history

Approve suppliers

Ensure food is from approved suppliers

Attestation

58

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FSVP: Compliance Dates

• Importers must comply with this rule:

• May 27th, 2017 (18 months after publication of

final rule)

OR

• 6 months after supplier must comply with

Preventive Controls or Produce Safety

• For exporters:

• Exporters must make sure they comply with the

appropriate FSMA rules to continue doing business

with companies in the U.S.

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FSMA: Accredited Third Party

Certification Rule

FDA

FDA would recognize accreditation bodies (ABs) based on certain

criteria such as competency and impartiality.

Accreditation Bodies

ABs would accredit qualified third-party certification bodies (CBs).

Third-Party Certification Bodies

Third-party CBs would audit and issue certifications for foreign

facilities and foods.

Foreign Facilities

Foreign facilities may choose to be audited by an accredited CB.

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FSMA: Voluntary Qualified

Importer Program (VQIP)

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VQIP: Eligibility, Part 1

Food importer (in U.S. or abroad)

Can be different from CBP “importer of record”

Three-year history of importing food into the U.S.

DUNS number

Use paperless filer/broker with passing rating during last

FDA Filer Evaluation

No food is subject to an import alert or Class 1 recall

(whether or not food is brought in under VQIP)

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VQIP: Eligibility, Part 2

No ongoing FDA administrative or judicial action

No history of significant non-compliances with food

safety (e.g., “Official Action Indicated”)

Each foreign facility has current certification

VQIP Quality Assurance Program (QAP)

Within past three years, no CBP penalties

Pay annual VQIP user fee before Oct. 1st

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VQIP: Certification

To obtain food from foreign suppliers under VQIP, each

foreign facility must have a current food facility

certification issued by a third-party auditor/certification

body accredited by FDA

Annual recertification

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VQIP: Application

Submit “Notice of Intent to Participate in VQIP”

between January 1st and May 31st for the next fiscal year

A VQIP Application must include:

Applicant info and firm information

FSVP Responsible Contact

VQIP Quality Assurance Program

Filer/Broker Information

Foreign Supplier Facility and Products

Fee - $16,400

Resubmission

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VQIP: QAP

The VQIP Quality Assurance Program must include:

Corporate Quality Policy Statement

Organization Structure and Functional Responsibilities

Food Safety Policies and Procedures

Food Defense Policies and Procedures

Training for VQIP Employees

Implementation Procedures

Records

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VQIP: After Approval

FDA will “ordinarily conduct a VQIP inspection” after

the application has been approved

After approval, the FDA will reevaluate eligibility every

three years

Application may be amended to add/remove certain

items each year, but not new food

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VQIP: After Approval

FDA can revoke your VQIP participation if:

You cannot meet the VQIP eligibility requirements (no refund)

Evidence of participation in smuggling or fraudulent activities

FDA will send a “Notice of Intent to Revoke” and allow

the importer 30 days for corrective action

FDA will share revocation with other federal agencies

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VQIP: Pros and Cons

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FSMA: Produce Safety

70

FDA has finalized its Produce Safety rule under FSMA

Under this rule, foreign and domestic agricultural

facilities must ensure that their practices are up to FDA

standards, especially:

Agricultural water

Biological soil amendments of animal origin (fertilizers)

Employee training

Employee health and hygiene

Equipment, tools, buildings, and sanitation

Sprouts

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FSMA: Produce Safety

71

Who is affected?

Domestic and imported produce

Produce for human consumption

Who is exempt?

Less than $25,000 in produce

Produce rarely consumed raw

Produce for personal or on-farm consumption

Who has modified requirements?

Produce with a “kill step”

<$500,000 in all food sales, majority to “qualified end-user”

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FSMA: Produce Safety

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What are variances?

A foreign government may petition to have a “variance” from

a particular provision under the produce safety law

The petition must include:

Why the variance is necessary, i.e. local growing

conditions, local climate

How the hazard will be controlled under the variance

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FSMA: Produce Safety

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FSMA: Sanitary Transportation

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Final rule due by March 31st, 2016

Establishes requirements for:

Vehicles and transportation equipment

Transportation operations

Employee training

Records

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FSMA: Sanitary Transportation

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Does it apply to me?

Does not apply to transportation wholly in another

country (i.e., transportation of food solely in

Thailand)

Applies to transportation that enters the U.S.

Exceptions for shippers/carriers with less than

$500,000 in annual sales

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FSMA: Intentional Adulteration

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Final rule due by May 31st, 2016

Requires food facilities to:

Develop a written food defense plan

Identify possibilities for intentional adulteration

Create mitigation strategies

Monitor

Corrective action

Verification

Training personnel

Records

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FSMA: Intentional Adulteration

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Does it apply to me?

Exemptions for “qualified facilities”

<$10,000,000 in sales

Holding food

Alcohols

Produce rule

Animal food

Only packing

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FSMA Summary

2015 saw significant progress in implementing FSMA

FDA is set to have adequate funding to actually

implement FSMA

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2/23/2016

U.S. FDA

Import Alerts and Use of

DWPE

How to Petition FDA

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An Issue of Resource Management

25-30 million entries per year Food, drugs, medical devices, and cosmetics

Over 300 possible ports of entry

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What is an Import Alert?

Notice to all entry ports that certain products from

specific areas or manufacturers may be violative

Created whenever FDA discovers a pattern of violation

that creates a reason to believe that future shipments

may be similarly violative

Instructs FDA compliance officers to detain these

products without physical examination (DWPE)

More than 250 active Import Alerts

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36 Seafood-Specific Import Alerts

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Additional Import Alerts

Related to Seafood & Other Products

99-19 DWPE for presence of Salmonella

99-22 DWPE for lack of allergen labeling

99-39 DWPE for misbranding/nutrition labeling

45-02 DWPE for containing illegal colors

Etc…

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Types of Import Alerts

List Import Alerts:

Subject to the alert unless you’re on the Green List

List Import Alerts:

Only subject to the alert if you are on the Red List

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Types of Import Alerts

List Import Alerts: Inherently risky products from anywhere in the world

• 16-20 – Puffer Fish (Tetrodotoxin)

Violations common or widespread in certain regions

• 16-07 – Dried or Pickled Finfish from Thailand (Filth)

• 16-35 – Raw and Cooked Shrimp from India (Filth/Decomp/Salmonella)

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Types of Import Alerts

List Import Alerts:

Based on the nature of the violation or history of the company

16-04 – Misbranded Seafood

16-120 – Foreign Processors Not in Compliance with Seafood HACCP

99-19 – Food Products due to Salmonella

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Detention Without Physical Examination

(DWPE)

Shipment will be detained without inspector even

looking at it

Works under the premise that the products appear

violative based on a history of violation

NOT an automatic refusal

The importer must present evidence to FDA that the product is

NOT violative in order to get a shipment released from

detention

This process will repeat for ALL shipments for as long as the

Import Alert is in effect

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16-22

Canned Shrimp from Thailand

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16-22

Canned Shrimp from Thailand

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16-47

Red Snapper from Thailand

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Thailand’s Import Alerts

Thailand is currently subject to 46 import alerts

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FDA Import Alerts

What do you do if you find yourself or your

supplier subject to DWPE?

PETITION!

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Removal from DWPE

A firm will remain subject to DWPE unless it provides

evidence to FDA that it is no longer at risk

Petition sent to Division of Import Operations (DIO) to

request removal

May be 100+ pages in length

Requires extensive documentary evidence

DIO reviews petition, which can take months before a

decision is made

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Petition Requirements

Documentary evidence that the problem has been

corrected or prevented Will vary depending upon the circumstances (e.g. a revised HACCP plan,

change of suppliers, label revisions, lab analyses of every lot, etc.)

A series of non-violative shipments to verify that the

corrective or preventive actions are sufficient Minimum of 5-12 shipments

Submission of shipping documents

• US Customs Form 3461 or 7501

• Commercial Invoice

• Packing List

• Bill of Lading

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2/23/2016

FDA Inspections

Why & How to Prepare

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Why Me and Why Now?

• You consent to FDA inspections with your food facility registration

• Facility’s risk profile:

• Commodity specific

• Manufacturing process

• Compliance history

• Could be as simple as you are located near another facility FDA will inspect

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High Risk Foods

•Acidified Foods

•Low-Acid Foods

•Seafood

•Custard Filled Bakery

Product

•Modified Atmosphere

Packaging

•Dairy Products

•Soft; Semi-soft; Soft Ripened

Cheese and Cheese Products

•Unpasteurized Juices

•Sprouts Ready-to-Eat

•Fresh Fruits and Vegetables

•Processed Fruits and

Vegetables

•Spices

•Shell Eggs

•Sandwiches

•Prepared Salads

•Infant Formula

•Others

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Inspection Process:

“Notice of Inspection”

• Notice is sent by email to

registrant’s email as

indicated in the food

facility’s FDA registration

• Notice is also sent to U.S.

Agent via email

• Email will come from:

@fda.hhs.gov

• Key Points:

• 5 Days to Respond

• Provide additional

data

• Refusal to respond or

refusal to allow an

inspection may cause

“increased sampling,

refusal of admission,

or other regulatory

action.”

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Inspection Process: “Factory Profile

Information” Form

• Once you reply, FDA’s Office of Regulatory Affairs

will contact you:

• May take days, weeks, or months (or never)

• Coordinate inspection date

• Ask you to complete and return a “Factory Profile Information”

form to FDA

• FDA will then come back with name of investigator, their flight

info, ask you to make hotel reservations, and maybe even ask you

to provide ground transportation.

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Inspection Process: Day 1

• Inspection is typically 2 days

• Day 1:

• Introductions

• Opening Meeting

• Quick Tour

• Document Review

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Inspection Process: Day 2

• Day 2:

• Most time spent in factory

• Closing meeting with management

• Delivery of form “483” “Inspectional

Observations”

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Inspection: Focuses

• Focus on processes

• HACCP/HARPC (in future, Food Safety Plan)

• Focus on personnel

• Focus on facility construction & grounds

• Focus on sanitation

• Focus on equipment & utensils

• Focus on warehouse/distribution

• Focus on records

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Applicable FDA Regulations

A single inspection may focus on multiple

requirements

For example, canned sardines may be inspected for

compliance with:

Seafood HACCP (21 CFR 123)

Low Acid Canned Foods (21 CFR 113)

Current GMP (21 CFR 110)

Food Labeling (21 CFR 101)

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End of Inspection

• Closing Meeting: Discussion of observations with

management (CEO, Plant Manager, QA / QC Managers)

• Opportunity to have corrective actions of the

deficiencies identified by FDA Investigator reviewed

before inspector departs

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End of Inspection

• Inspector departs with no

observations

or…

• Form FDA 483 (Inspectional

Observations) is issued

• Outlines Observations /

Deficiencies

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After the Inspection

• Facility responds to FDA

483

• FDA reviews response to

FDA 483

• FDA issues an

Establishment Inspection

Report (“EIR”)

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After the Inspection

• FDA will eventually classify the

inspection:

• No Action Indicated (NAI)

• Voluntary Action Indicated (VAI) -

• Official Action Indicated (OAI)

• FDA discloses the final inspection

classification in an online database

• http://www.accessdata.fda.gov/scripts/inspsearch/

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OAI Actions

• Warning Letter (which

you could respond to) and

perhaps a “Close Out

Letter”

• Detentions at the port

• Registration suspension

• Re-inspection under

FSMA

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Inspection Process: Summary

Notice of Inspection

Request for more information

Inspection

FDA Form 483 issued

Corrective Action

Response

Establishment Inspection

Report

Classification

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2/23/2016

Summary & The Year Ahead

What’s in Store for 2016

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Common Themes for 2016

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Common Themes for 2016

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Common Themes for 2016

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Labeling Changes for 2016

FDA has issued two proposed rules and one

supplemental proposed rule related to nutrition

labeling.

Final rule is scheduled to be published in March 2016.

Industry will have two years to comply after the

effective date stated in the final rule.

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Highlights of the Proposed Rules

Calories and Serving Sizes made more prominent

Percent Daily Values moved to the left side of the label

Potassium and Vitamin D must be declared; Vitamins A and C

now optional

Calories from Fat declaration removed

Update to the daily values for certain nutrients

Declaration of Added Sugars and %DV (10% of total calories)

Changed the current footnote to "*The percent daily value (%DV)

tells you how much a nutrient in a serving of food contributes to a

daily diet. 2,000 calories a day is used for general nutrition

advice."

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Highlights of the Proposed Rules

Replace "Total Carbohydrate" with "Total Carbs"

Change "Amount Per Serving" to "Amount Per [actual size]" e.g.,

Amount Per ½ cup

Revision of serving sizes to reflect what Americans actually

consume

Require certain packaged foods be labeled as a single serving if

typically eaten in one sitting (e.g., 20 oz soda)

Require dual column labels on certain packages for products that

could be consumed in one or multiple sittings ("per serving" and

"per package")

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Original vs. Proposed Charts

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Common Theme for 2016:

FDA Compliance Monitoring

FSMA requires firms to “monitor” the FDA compliance

of their suppliers

Preventative Control Rule

Foreign Supplier Verification Program

Voluntary Qualified Importer Programs

Concept is simple: importers must check the compliance

of their suppliers, foreign and domestic

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FDA & Your Company’s Digital Footprint

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FDA Compliance Monitor

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Summary, Solutions, and Questions

Registrar Corp provides a full range of fixed-fee

compliance services:

Registration & U.S. Agent Service

FSMA Compliance Package (includes FSVP audit)

Prior Notice Filings

Label, Ingredient, and Product Review

LACF and Food Safety Services (Mock FDA Inspections, etc)

Detention Assistance

DWPE Petition Submissions

FDA Compliance Monitor

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FSMA Compliance Package

FDA Foreign Supplier Compliance Package

Food Safety Plan Review (up to three products)

FDA Compliance Monitoring (up to 50 facilities)

Onsite Food Safety Audit (FSVP Audit) (excludes travel and

lodging)

Food Defense Plan Creation or Review

Labeling and Ingredient Review (up to three products)

FCE-SID Process Filings (unlimited)

Food Facility Registration and U.S. Agent Service (as required

under 21 CFR §1.225)

Detention Assistance

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Contact Us

Registrar Corp Headquarters

144 Research Drive

Hampton, Virginia

USA 23666

P: +1-757-224-0177

F: +1-757-224-0179

E: [email protected]

www.registrarcorp.com

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Registrar Corp Worldwide Offices

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