Are you in compliance with the FSMA Foreign Supplier Verification Program Rule?

Neal Fortin - April 02, 2024

View or read a quick overview of the FSMA FSVP Rule and why some companies are non-compliant.

Don't be caught not knowing your responsibilities. Learn what you need to do to import individual ingredients or entire foods into the United States. Neal Fortin, Director of MSU's Institute for Food Laws & Regulations, has seen more frequent FDA citations and even deadly mistakes resulting in recalls. Watch this 2.5 minute video or read the transcript below for more information. Learn about the upcoming online summer course on the FSVP rule here.

Disclaimer.

Transcript

By and large, food businesses know about FSMA, the Food Safety Modernization Act. However, a crucial but lesser known part of FSMA is the Foreign Supplier Verification Program, FSVP. This program is one the most significant changes in US food law and puts responsibility squarely on the shoulders of importers to ensure that imported food meets the same safety standards as domestically produced food.

You may not even know that you are considered an importer under the Foreign Supplier Verification law. If at the time of entry into the US, you own the food, have purchased the food, or have agreed in writing to purchase the food, you are the importer under the Foreign Supplier Verification law.

Under this law, the importer must both ensure the safety of imported food and also document verification of the safety. To that end, food importers must have a properly trained Qualified Individual to oversee their FSVP responsibilities. The qualified individual must document their verification that an appropriate food safety plan has been implemented and followed at every step in the supply chain.

All reasonably foreseeable hazards, including microbiological, chemical, and physical hazards, must be addressed, and the controls verified. This requires a written hazard analysis, written evaluation of the food supplier performance, and documentation of other verification activities, including the safety of all food ingredients and additives.

Two major and significant violations of the Foreign Supplier Verification law repeatedly cited by the FDA are the failure to have a FSVP Qualified Individual and failure to develop a foreign supplier verification plan.

Disclaimer.

The Institute for Food Laws and Regulations at Michigan State University can help you understand your responsibility under the law. Understanding this law can help prevent costly regulatory delays, import denial, and more severe problems.

Join us for an online graduate course on the FSMA FSVP Rule.
The course is asynchronous and runs May 13 - June 27, 2024.

Course Overview

IFLR's Scott Haskell has updated IFLR's online course on the FSMA Foreign Supplier Verification Program Rule. This course provides students with the knowledge and understanding to implement the requirements of the FSVP. The course materials provide an understanding of the key requirements for the development and implementation of an FSVP. Record keeping systems are emphasized that meet the regulatory requirements to import foods into the USA.

The course runs from May 13-June 27, 2024.

Topics covered include:

Overview of FSMA
FSVP requirement overview
How to develop and implement a FSVP plan
Foods that cannot be consumed without control of hazards
Foods whose hazards are controlled after importation
Corrective actions and investigations
Importer identification at entry
Record keeping
FDA oversight
Dietary Supplements
US importers of Canadian foods
Very small importers and food from certain small suppliers
Analysis of economic and environmental impact
Understanding the changing landscape of FSVP regulations
Countries with comparable or equivalent safety systems
Compliance dates
Executive Order 13175
Best practices for compliance with FSVP regulations

Cost

MSU's Lifelong enrollment tuition for the 2023-2024 academic year for non-Michigan residents, including international residents, is $3,333.00 USD per 3-credit course. Tuition for Michigan residents is $2,601.00 USD per 3-credit course. All IFLR courses are 3-credits.

We offer a lower rate of $1,850.00 USD for non-credit registration, if you wish to take our courses for "informational purposes only," rather than work toward a certificate or eventual degree. Click here for non-credit enrollment.

Enrollment Help

You may read more about what to expect from an IFLR course on our "Details" page.

You may read more about our enrollment process at our "Enroll" page.

Please contact Mary Gebbia at iflr@msu.edu with any questions about our courses or enrollment process.

Tips for First Time Enrollees

Here is the direct link to apply: https://explore.msu.edu/apply/

Make sure you choose “first-time user” and then “NON-DEGREE” from the dropdown. There is no application fee for our program, so if you get to an area where it asks you to pay an application fee, then you are not in the correct process. Also, DO NOT CLICK THE BOX that asks if you are going to be taking classes in the global food law program. That question is referring to courses through the College of Law and saying “yes” to that question will only delay your application processing."

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Click here to learn more about our online certificate programs.

MSU's Institute for Food Laws and Regulations offers online graduate courses to food industry professionals. Most IFLR students work full time for food companies or regulators, and take one online course at a time to further their professional development. Students may take as few or as many courses as they desire, and may earn a Certificate in International or United States food law after completing twelve qualifying credits (usually four courses).