Do we automatically meet FSMA requirements if we have SQF certification?
SQF /GFCI and SQF/BRC work closely with the FDA on developing the FSMA requirements. 2 requirements that are included in FSMA are really not protected by SQF/BRC, which are PCQI, FSVP and possibly the newest regulations of the Adulteration of Human Foods.
We at MEP recommend, and the FDA require, that each manufacturing location have a registered PCQI and are aware of FSVR requirements. Because of the importance of these competencies MEP suggests backups and there for multiple of trained individuals. The cost of training for these courses is relatively inexpensive ($750 – $1000) as compared to the cost / expense of failing an FDA Audit.
PCQI can be a company employee or an outside consultant. The PCQI is the only person that can sign a food safety plan in a facility. When and if the FDA audits a particular facility they will know if you have a registered PCQI form your facility. The audit will be tempered if you do.
What happened to HACCP?
Preventative controls PCQI identifies certain points in the manufacturing line that can cause food safety issues and identifies the problems when they occur. The new FSMA regulations are preventative in natural. That is why they are called Preventative Controls for Human Food.
Am I required to have FSVP (Foreign Supplier Verification Program) training?
No, you are not required to have FSVP program training. You are required to comply with the law. Violation of stated requirements is subject to penalties, both criminal and civil.
What are the levels of certification you can receive in the food industry?
There are two separate segments to compliance.
Government Compliance – rules and regulations required by the FDA and potentially by the local governments.
Commercial Compliance – requirements put forth by a client or purchaser on a manufacturer.
The commercial compliance is at multiple levels and requires a third party audit from companies such as NSF, ABI, etc. They will start their audits by reviewing your SOPs and GMPs, auditing you periodically and providing you with a quality score.
Third part Audits on GMP’s is the minimum requirements many large retailers ask manufacturers to comply with. Higher level Food Safety Certifications include – SQF, BRC, FSSC 22000. The most popular one in the U.S. is SQF followed by BRC, which can be for both distributors and manufactures. FSSC 22000 is the closest thing to ISSO certification and goes beyond food safety and quality throughout the while business process. Both SQF and BRC, depending how prepared you are for the audit, takes 6 months to a year to get audited and certified.
Where can I get training on these certifications?
Supplies training on the following items for food safety are as follows:
|HACCP||Preventative Controls For Human Foods|
|SQF Practitioner||Food Allergies|
|Food Recall and Withdrawal||GMP Requirements & Readiness|
|Internal Auditing||Internal Auditing for Food Safety Management Systems|
|Food Defense||Corrective Action and Root Cause Analysis|
|SQF Implementation||BRC Implementation|
|FSSC 22000 Implementation||Foreign Supplier Verification|
They are provided by a regular schedule at the NE MEP Centers.
Can you help me with other areas in food production?
MEP centers provide assistance in plant operations efficiency under the umbrella of lean manufacturing processes. In many cases, the individuals or consultants doing the assisting have experience in the production and manufacturing of food. MEP centers also offer assistance with identifying employees, HR practices and financial assistance in the areas of R&D Tax credits.
What are SQF and BRC used for?
Many large retailers and/or manufactures require BRC or SQF certification, which is a minimum requirement to initially be on their bidders list. Many require your certification after 6 to 8 months. Because of this we consider these certifications as a growth platform; giving you the manufacturers the ability to sell your product in locations you did not have the ability to do so before.
Can you tell me what the latest food Labeling requirements are and did they change in the last 12 months?
We offer a brief summary of what these changes are. The new labeling requirements from the new NJMEP website are available. NJMEP will be offering additional classes in 2018.
Click Here Food Labeling Guide
Are government subsidies available to help me be in compliance with FSMA?
Yes, the subsidies vary widely and we recommend you contact your local MEP center in your state to see what subsides are available. In addition, we recommend that food manufactures take advantage of R&D Tax Credits.
R&D Tax Credits are available from the federal government, and in some cases the state government. They represent 6 to 10 percent in QRE – Qualified Research Expenses. Examples of QRE’s are development of new recipes, implementation and training on new machinery and new manufacturing techniques. The funding on these tax credits can be applied to business needs, but we suggest it gets reinvested in preparation for FSMA.
I need to move to a new facility. Can a MEP center help?
The MEP centers in every state usually have alliances with the EDA organizations in every state. If they can’t provide direct assistance, they can connect you with authorities that can help.