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FSMA Proposes Rule for Foreign Supplier Verification Programs Published Date : 2013-09-05 13:13:41

On July 26, 2013, FDA issued proposed regulations that would greatly strengthen the oversight of foods imported for U.S. consumers. Under the Foreign Supplier Verification Program (FSVP) regulations, importers would be required to perform certain risk-based activities to verify that food imported into the United States has been produced in a manner that provides the same level of public health protection as that required of domestic food producers. The FSVP regulations would implement section 301 of the FDA Food Safety Modernization Act (FSMA).

The proposed regulations vary based on the type of food product (such as processed foods, produce, and dietary supplements), the category of importer, the nature of the hazard in the food, and who is to control the hazard.Background

Food arrives in the United States from farms and producers around the world. About 15 percent of the U.S. food supply is imported, and for some commodities, such as produce, that percentage increases greatly. It is important that food imported into the United States meets the same level of public health protection as food produced domestically.

FSMA, signed into law on January 4, 2011, enables the FDA to better protect public health by helping to ensure the safety and security of the U.S. food supply. The vision of FSMA is prevention — preventing food safety problems before they occur, rather than reacting to problems when they happen. One of the most significant changes that FSMA made to FDA’s food safety authorities is in the area of imports. These new import authorities will help FDA transition from its historical focus on catching food safety problems at the border to one that builds safety in throughout the supply chain, from foreign producers to U.S. consumers.

Although FSMA directs the FDA to increase its inspections of foreign food facilities, Congress also provided FDA with the authority to develop regulations that would require industry to share responsibility and be accountable for preventing food safety problems.Highlights of the Proposed Rule

FSVP Requirements

All importers must establish and follow an FSVP, unless otherwise exempted. An importer of food under the proposed FSVP regulations is the U.S. owner or consignee of the food at the time of entry, or, if there is no U.S. owner or consignee at the time of entry, the U.S. agent or representative of the foreign owner or consignee. Under the proposed FSVP regulations, an importer would be required to develop, maintain, and follow an FSVP for each food it imports, which, in general, would need to include the following:

Compliance Status Review: Importers would be required to review the compliance status of the food and the potential foreign supplier before importing the food and periodically thereafter. Such review would need to include any FDA warning letters, import alerts, and requirements for certification issued by the FDA under section 801(q) of the Food, Drug, and Cosmetic Act (FD&C Act).

Hazard Analysis: Importers would be required to analyze the hazards associated with each food they import. The hazard analysis would identify the hazards that are reasonably likely to occur for each type of food imported, and evaluate the severity of the illness or injury if such a hazard were to occur.

Verification Activities: Importers would be required to conduct activities that provide adequate assurances that the hazards identified as reasonably likely to occur are adequately controlled. Verification activities could include: onsite auditing of foreign suppliers; periodic or lot-by-lot sampling and testing of food; and periodic review of foreign supplier food safety records; or other appropriate risk-based procedures. Verification activities applicable to all FSVPs, regardless of identified hazards, include maintaining a written list of foreign suppliers from which food is imported, and establishing and following adequate written procedures for conducting verification activities.

Corrective Actions: Importers would be required to review complaints they receive concerning the foods they import, investigate the cause or causes of adulteration or misbranding in some circumstances, take appropriate corrective actions, and revise their FSVPs when they appear to be inadequate.

Periodic Reassessment of the FSVP: Importers would be required to reassess their FSVPs within three years of establishing the FSVP or within three years of the last assessment. However, importers would have to reassess the effectiveness of their FSVP sooner if they become aware of new information about potential hazards associated with the food. Examples of such information might include information on changes to the source of raw materials or to product formulation.

Importer Identification: Importers would be required to obtain a Dun and Bradstreet Data Universal Numbering System (DUNS) number for their company and to ensure that, for each food product offered for importation into the United States, their name and DUNS number are provided electronically when filing for entry with Customs and Border Protection.

Recordkeeping: Importers would be required to keep certain records, including those that document compliance status reviews, hazard analyses, foreign supplier verification activities, investigations and corrective actions, and FSVP reassessments.

Control of Hazards

The FDA is proposing a flexible, risk-based approach to foreign supplier verification. The proposed regulation focuses on foreseeable food safety risks identified through a hazard assessment process, rather than all risks covered by the adulteration provisions in the FD&C Act. Because the principle of hazard assessment is well accepted and understood throughout the food industry, the FDA believes that it provides the most effective way to implement a risk-based

framework in which importers can evaluate potential products and suppliers and conduct appropriate verification efforts.

The requirements for supplier verification in the proposed rule on FSVP are primarily based on who is to control the hazards that are reasonably likely to occur with a particular food and the nature of the hazard. In the proposed rule, the FDA is proposing two options for the supplier verification activities for hazards that the foreign supplier will control or that the foreign supplier verifies are being controlled by its raw material or ingredient supplier.

Option 1

Under Option 1 of the proposal, if the foreign supplier controls the hazard at its establishment and there is a reasonable probability that exposure to the hazard will result in serious adverse health consequences or death to humans or animals (SAHCODHA), the importer would be required to conduct or obtain documentation of onsite auditing of the foreign supplier. Onsite auditing would also be required for microbiological hazards in certain raw agricultural commodities. For non-SAHCODHA hazards that the foreign supplier controls, the importer would be required to conduct one of more of the verification activities mentioned above (onsite auditing, sampling and testing, review of the supplier’s food safety records, or some other appropriate procedure) before using or distributing the food and periodically thereafter. In determining the appropriate verification activities, the importer must consider the risk presented by the hazard and the food and foreign supplier’s compliance status.

Option 2

Under Option 2 of the proposal, for all hazards that the foreign supplier will either control or verify that its supplier is controlling, importers would need to choose a verification procedure from among onsite auditing, sampling and testing, review of supplier food safety records, or some other appropriate procedure. In determining the appropriate verification activities and how frequently they should be conducted, the importer would need to consider the risk presented by the hazard, the probability that exposure to the hazard will result in serious harm, and the food and foreign supplier’s compliance status.

If the importer, rather than the foreign supplier or its supplier, will be responsible for controlling a hazard that it has identified as reasonably likely to occur, the proposed rule would require the importer to document, at least annually, that it has established and is following procedures that adequately control the hazard. If the importer’s customer will be controlling a hazard identified by the importer, the importer would need to obtain written assurance, at least annually, that its customer has established and is following procedures (identified in the written assurance) that adequately control the hazard.

The proposed rule also states the FDA’s intent to align the supplier verification provisions in the FSVP regulations with any supplier verification provisions that are included in the final rules on preventive controls for human and animal food. This would avoid imposing duplicative requirements on entities that would be subject to both the FSVP and preventive controls regulations (because the entity is both a food importer and a registered food facility).

Modified Requirements and Exemptions

Under the proposed rule, modified FSVP requirements would apply in certain circumstances, including the following:

Importation of a dietary supplement or dietary supplement component;

Importation of food by a very small importer or importation of food from a very small foreign supplier; and

Importation of food from a foreign supplier in good compliance standing with a food safety system that FDA has officially recognized as comparable or determined to be equivalent to that of the United States.

The proposed rule would exempt the importation of the following from the FSVP requirements:

Juice and seafood from facilities that are in compliance with the Hazard Analysis & Critical Control Points (HACCP) regulations, which contain their own supplier verification provisions;

Food imported for research or evaluation purposes;

Food imported for personal consumption;

Alcoholic beverages; and

Food that is transshipped or imported for further processing and export.

Effective and Compliance Dates

The FDA is proposing that the FSVP regulations become effective 60 days after the final rule is published in the Federal Register, but FDA is proposing to provide additional time before importers would be required to come into compliance. The compliance dates would vary depending on the circumstances. In general, the compliance date would be 18 months after the publication date of the final FSVP regulations. However, recognizing that the FSVP proposed rule is closely tied to the proposed rules on preventive controls and produce safety, the compliance dates for importers in many cases would depend on the compliance dates for those rules. In general, the importer would be required to comply with the FSVP regulations six months after the foreign supplier of the food is required to comply with the new FSMA preventive controls regulations.Economic Impact of the Proposed Rule

The proposed rule is aimed at reducing the public health burden of foodborne illness by helping to ensure that imported food is produced in compliance with applicable food safety regulations. The annual cost of the illnesses associated with imported foods that would be subject to the FSVP regulations is approximately $1.18 billion, which is more than one-fifth of the entire estimated burden of illness related to foods consumed in the United States.

For option 1, the proposed rule has a first-year cost to industry of $492 million and an annualized cost of $473 million, ,using a 7 percent discount rate according to Office of Management and Budget guidelines.

For option 2, the proposed rule has a first-year cost to industry of $480 million and an annualized cost of $462 million, using a 7 percent discount rate according to Office of Management and Budget guidelines.

View the entire Preliminary Regulatory Impact Analysis.Rulemaking Process and How to Submit Comments

When the FDA issues a proposed rule on a matter, it publishes the proposed rule in the Federal Register so that the public can review it and submit comments. The FDA considers comments received during the comment period on a proposed rule and then considers revising the rule based on the Agency’s review of the comments before issuing a final rule. In the preamble to the final rule, we discuss the significant comments received. The proposed and final rules and supporting documents are filed in the FDA’s official docket on http://www.regulations.gov and also can be accessed at http://www.fda.gov/fsma. Comments on the proposed rule “Food Supplier Verification Programs for Importers of Food for Humans and Animals,” which publishes in the Federal Register on July 29, 2013, are due by 120 days after the publication date.

The FDA has conducted extensive outreach to industry, the consumer community, other government agencies, and the international community to gain input and perspective on how to structure this and other proposed rules to implement FSMA. That input and perspective helped shape the proposed regulations in a way that will help to ensure that they are practical and flexible as well as effective. The FDA held a public meeting on FSMA provisions concerning imported food, including FSVPs, in March 2011, and we will be holding three additional public meetings during the comment period on the FSVP proposed rule.Assistance to Industry

The FDA plans to publish, at the time of the final rule on FSVPs, draft guidance to assist importers in developing and following FSVPs as well as how to comply with the other requirements of the FSVP rule.

Spicing up Salmonella Published Date : 2013-09-05 10:25:42

I love Asian food, but I am taking a closer look at the ingredients and how I am using them. The sourcing of herbs and spices will come under the spotlight more frequently in future. The USA imported 326,000 tonnes of spices last year and recent investigations found that several shipments were contaminated with salmonella and those shipments from Mexico (14%) and India (9%) were the more frequent sources of contamination. The same research indicated that some 15% of coriander, 12% of oregano and 4% of black pepper samples were contaminated. In Newcastle upon Tyne a large outbreak at the city’s Spice Street Festival affected 400 people in February this year. The cause was the use of uncooked imported dried curry leaves which were added, without cooking, to the chutney. I suppose some may say that it is of less risk in pre-cooked ready meals because the cooking process will act as an effective CCP. Even if that is the

case what are the cross contamination risks from handling that raw ingredient on other parts of the operations? Who would want a known salmonella contaminant sitting in the warehouse? The Indian spices board has started a program to improve the farming of spices by offering grants to encourage the installation of concrete drying platforms, tarpaulins and netting and introducing modern techniques for reducing contamination. In time this will contribute to reducing this risk. In the meantime the identifying and monitoring of assured ingredients sources is certain to continue to be a challenge. In my refrigerator sit two ready meals with at least six spice/herb ingredients listed. If each spice or ingredient came from one farm that’s a decent amount of supplier auditing and supplier risk assessment.

Damned if you do recall and damned if you don't Published Date : 2013-09-04 13:09:56

Earlier this month we were all aware of the Fonterra botulism scare and the media coverage was vast with states such as China banning imports of New Zealand whey powder etc.

Now it all turns out to be false alarm.

From a brand protection perspective they have suffered a big hit, but if they had delayed the announcement and it had been positive they would also have taken a hit. Damned if you do and damned if you don’t.

But have a thought also for all those other food companies who we frantically looking at the implications on the supply chain risk management strategies and frantically searching food specifications and customer specifications to see if they contained whey powder from New Zealand. Without specification management software this will have been a time consuming, and eventually unnecessary task. Until the next scare.

Supply chain risk management is receiving increased attention, the distraction of false alarms is not ideal.

Losses from recalls and profits from food safety Published Date : 2013-09-02 21:59:05

Thoughts were triggered by recent stories about a report from the US based Wipro Council for Industry Research.

The report kicks off with the statement that food recalls cost the US food industry $20 billion every year. The costs to the companies directly involved and the costs to the product sectors that suffer from the fall-out of consumers avoiding all similar products were included.

The report quotes research that 58% of the food companies questioned had admitted to a major recall in the previous five years. Furthermore as many as 78% admitted to managing the risks through insurance.

So 11% to 12% of US food companies were involved in recalls each year and nearly a quarter of them experienced losses of more than $30 million per recall.

With costs like that the insurance premiums must be huge. Assuming a company survives a major recall with the help of the insurance company then what would be the premium the following year?

The report points to the attitude within US food companies that food safety management is a drain on profits with no apparent benefit. ”Experts equate investments in food safety initiatives to investments in life cover—high premium with low returns.” So it would seem that some US food companies are not giving their food processing management enough money for food safety. Surely they have some form of supplier accreditation and supplier approval?

Am I being too simplistic to think that perhaps if the US food industry invested ‘only’ $5 billion a year in proven food safety systems and halved the cost of recalls then there would be some benefit to the profitability of food companies?

Don’t forget to add the extra profits gained from unexpected consequences. Ask the 3000 plus companies in the USA that have already achieved food safety certification to GFSI recognised systems. Has quality consistency improved? Have process errors reduced so that re-work or scrapping occurs less frequently?

Have the standards of ingredient supplies improved? Are there fewer rejected deliveries and returns? Has the level of consumer complaints and customer complaints reduced?

….and have their recalls reduced?

Bird Flu Flies Back Published Date : 2013-08-30 10:22:06

The new strain of bird flu, H7N9, was reported to have crossed into humans in China in March this year. Reports then told us that it had reached Taiwan and recent information has told us of an

outbreak on three Italian farms. Earlier in August the first case of human to human contagion was identified when a father passed the infection to his daughter who was caring for him.

At its peak in 2006, the H5N1 bird flu was reported in 60 countries, with the highest number of cases in Indonesia, Vietnam, China, Thailand and Turkey. In the past bird flu has mainly infected humans who have had close unprotected contact with live infected poultry. There has been no cases of people catching the virus from eating poultry meat.

From past experience that may not stop some consumers reducing their consumption. The main concern for businesses using poultry meat or eggs as an ingredient in their products may be a potential impact on supply. Italy, though working to isolate the outbreak, is still a major European producer of carcasses, meat and eggs. Perhaps now is the time for poultry users to review the security of their supply chain. More than one supplier? More than one country of supply?

This raises a number of questions. If you need to appoint a new supplier in a hurry how quickly can you complete your supplier risk assessments? Will your present risk management system get the job done in time for you to confirm the new supplier?

It also gives politicians some food for thought when they consider the proposals from some parties that labelling of products containing meat should declare the countries of origin. Imagine having to switch country of source quickly. Then four weeks later the virus has spread and you have to find another source in another country! That could be a lot of waste packaging as the outbreak spreads across the world.

On the other hand if your SAQ’s include pertinent questions regarding on-farm security and livestock health and they are up-to-date your risks will surely be much reduced.

Risk Assessments in Fine Dining? Published Date : 2013-08-27 19:57:58

Are there signs of an interesting trend in the attitude of the mass media toward the FSA and Food Safety? The weekend before last the Sunday Times carried a story about chefs of repute complaining about the intervention of food inspectors in advising about the dangers of producing dishes made from poultry livers that were lightly cooked.

This week we have seen the Daily Mail continuing this theme with Gourmet experts decrying the efforts of an EHO’s advice on the safety of offering rare cooked burgers. A court case had been concluded in which a local authority had made an effort to rein in a restaurateur they deemed to be incapable of preparing a beef burger safely if it was offered rare.

There may often be differing opinions in risk assessments carried out by two sides of a food safety argument. The food inspectors base their conclusions on the results of their audit and can

only assess the likelihood of a food borne outbreak on general facts. They know there is a higher risk of E.coli O157 from eating undercooked beef because the information from the FSA supports it. They know that the chances of being infected with Campylobacter from dishes using undercooked chicken liver are much higher because the information is there to ’prove’ it.

The chef’s argue that they are trained, experienced and buy only from good suppliers. This may illicit a response tinged with incredulity from anyone in a part of the food industry where supply chain risk management involves more than just nipping round to the local meat and poultry wholesaler. However, there is a great deal to be said for personal contact and a history of safe supply. We may call it a supplier audit, but that visit to the local supplier for a chat over a cup tea can tell the buyer a great deal about the kind of business from which the ingredients are being obtained. Or can it?

If the feared outbreak happened whose evidence would weigh the heaviest in court? Would the burger maker’s argument last week still be favoured when his rare juicy burger offered an E.coli ruined kidney on the side?

The chef who takes a chance with his customer’s health and fails to protect them has no legal defence. He or she has been warned.  Being banned from running a food business is one possibility, but what of the consequences for the customers? Would the restaurants public liability insurance stand the cost or would the insurer tell the chefs that they failed to act with due care and therefore invalidated their cover?

Is this the perfect storm building in the ‘fine dining’ sector?

QADEX Welcomes Derrick Blunden Published Date : 2013-08-22 14:02:36

We are delighted to announce that the esteemed Derrick Blunden is now helping QADEX as we gear up our marketing efforts to help all of those food businesses who are not currently QADEX customers to come on board and enjoy working with QADEX to enable step change improvement in food safety and brand protection.

Food safety threat increase due to distraction Published Date : 2013-07-20 10:18:54

Everyone here in the European Food industry have been in such a spin over the past few months dealing with the waves of issues thrown up by the horsemeat scandal that I have worried privately that we are taking our eyes off the bigger picture.

At the time of writing, I am still not aware of any food safety impacts on consumers. Fingers still crossed.

But with everyone so focussed on the protein supply chain and species testing I worry that while the industry is distracted with this that other risks may get missed.

Food safety and supply chain risk management is an ongoing, long term project.

Today I have posted on my Linked in profile about Phosphates used as a pesticides on rice and wheat may have resulted in the childrens deaths in India this week. http://lnkd.in/-YR7Yt Will our UK food industry horizon scanning systems be agile enough to increase surveillance on rice and wheat originating from India, what about finished products containing rice and wheat as ingredients?

I have also posted about the possible Hepatitis A outbreaks linked to frozen imported berries, 10 people in Ireland fall ill with Hepatitis A, FSAI linking this to imported Frozen Berries used in fruit smoothie etc http://lnkd.in/CshVwa This strikes me as something we may hear more about over the coming months.

What really concerns me about this Hepatitis A outbreak is that this appears to have been flagged up over 4 weeks ago by the CDC in the USA and has been linked to 118 outbreaks of Hepatitis A

Food supply chain risk assessment and supplier monitoring systems could be proactive enough to increase surveillance on the implicated products if the industry knows what to look for.

As an industry we are a major contributor of taxes and employment to the UK economy, in return our various government agencies, and I am not bothered who, should be collating this data from around the world, and making it available free of charge to the food industry who can then use their specification management systems and supplier approval management systems to filter what issues may be a food safety risk in their business.

It is not reasonable to expect industry to tackle this alone and be damaged when yet another issue arises.

No matter how good supplier approval management, food specification systems and supplier monitoring is there will be things that slip through the net.

More can be done.

Anaphylaxis Campaign Conference (Part 2) Published Date : 2013-06-21 18:01:14

Liz Burgess, Scientific, Technology & Regulatory Business Partner at Kellogg’s gave a very insightful presentation “Making the FIC work: The view of a major manufacturer”

Liz raised many very pertinent issues from the perspective of a branded food manufacturer operating internationally.

Font size compliance was a bigger issue than I appreciated when you consider the range of packaging suppliers and repro houses in use.

The need to cluster languages on pack by geographic reason and how to organise these clusters was something which I had never considered before.

The implications of where packs are shared across countries, some in the EU and some not such as Switzerland opened up the whole debate about whether the FIC could be a restraint of trade.

Asda's learnings from the Horsemeat crisis Published Date : 2013-06-19 12:52:31

At the Anaphylaxis Conference last week there was a great presentation from Susan Mallin of Asda.

With reference to the horsemeat crisis there were a number of outcomes.

First, is a big increased focus on traceability and transparency down the entire food supply chainSecond, it was a wake up call to know what’s happening down the supply chainThird, do Asda really know where their ingredients come from

Yikes, I suspect that there is going to be a mountain of extra work coming the way of Asda suppliers.

Supplier risk assessments, supply chain risk management & supply chain compliance is going to get a level of focus unheard of in recent years.

Anaphylaxis Campaign Corporate Conference (Part 1) Published Date : 2013-06-17 11:38:03

I attended this great event last week at Runcorn.

Chaired by Tony Hines from Leatherhead Food Research there was a great line up of speakers.

Susan Mallin, Senior Technical Manager as Asda spoke about “Future challenges in the light of the Food Information for Consumers Regulation (FIC). Some of the effects from an Asda perspective were:1) Costs2) Supplier training and update of product specifications3) Manufacturing implications4) Education of the consumer

Across the Asda own label range over 13,000 food specifications require updating. Having specification management software already in place makes this task possible from an Asda perspective, but it is still a big undertaking for suppliers across the supply chain who may often have to get raw material specifications & packaging specifications to ensure updated finished product specifications are accurate.

As part of this process allergen risk assessments will also need to be updated to ensure that all allergen declarations are accurate.

This is a vast task for technical teams and one that is likely to result in intense pressure between now and the end of December 2014 when everyone needs to be compliant

The risk of adulteration of naturally derived food dyes Published Date : 2013-06-14 16:54:15

Speaking at the IFT expo in New Orleans in 2011, the director of US Pharmacopeia, Markus Lipp is quoted as saying

“For colorants, it’s the perfect storm: consumers are demanding it; they’re getting tougher to source”

“the signals are there. There’s a complacent public and overactive advertising philosophy going with it…there’s so much money that can be made so easily under the radar, you’re almost stupid if you are not doing it”

So how as a food industry can we feed this into our horizon scanning and ensure that our supplier audit and food safety risk assessments are robust enough to pick this up.

How many businesses have specification management software robust enough to quickly identify where across their entire operations naturally derived food dyes are being used.

Supplier monitoring & QA checks then need to be flexible and and well integrated to enable non-conforming product to be quickly identified.

Freshly baked Aussie bread made in Ireland Published Date : 2013-06-12 18:38:07

With all the angst about the length of the UK food supply chain it made me smile to read that Coles, one of the largest supermarket chains in Australia, is being taken to Federal court by the Australian Competition and Consumer Commission (ACCC).

The commission alleges that Coles are committing ‘false, misleading and deceptive conduct’ in the selling of their bread.

The goods are sold in many of the company’s supermarkets with an in-house bakery as “Baked Today, Sold Today” and “Freshly Baked In-Store”.

However the ACCC alleges that many of the products are par-baked at a different location before being delivered to the stores.

It also claims that some of the supermarket’s gourmet breads are in fact baked in Ireland.

I guess they are less likely to do unannounced audits as part of their supplier auditing program.

Brewer Fayre rolling out Buffet Place Published Date : 2013-06-12 16:09:50

As I sit here in a Premier Inn Hotel in Widnes in advance of the Anaphylaxis Campaign Conference tomorrow at Runcorn I cannot help reflecting on a new Brewers Fayre(Part of Whitbread) concept called Buffet Place.

Advertised as an all you can eat buffet from £5.99 per person.

I could not help having a wander in to have a look at noted that there was a majority of fried food available all washed down by unlimited fizzy drinks for £2.00 per head.

And boy was it busy, even though it was only a Monday night.

I did not consider to look at how they were managing restaurant nutritional information and how they will manage compliance with the food information regulation from 2015.

The deeper point here though is that Whitbread who also own Premier Inn and Costa know where the mass market is and have developed a concept that I fear will be successful and lead to me too operators.

Yet food retailers and manufacturers are vilified by media in general for not providing food that is healthy enough. Is this really fair or do we as a society need to relook at how we educate people about diet.

As an industry we do have a role to play, but consumers themselves may need to be more responsible for their intake.

It would be interesting to know what is the average calorific intake from a visit to Buffet Place.

I went elsewhere to eat so cannot comment on quality, but where I went did not provide an all you can eat buffet, was nearby and was not very busy!

GDA+ labels touted as an option to accentuate the positive Published Date : 2013-06-10 20:07:48

It is being reported that European food and drink companies are exploring a voluntary front of pack labelling scheme that would allow food companies to highlight positive nutritional credentials.

On top of GDA labelling and complying with FIR it seems that the sands are constantly shifting at the moment for those poor lonely souls responsible for food specifications at branded food companies in particular who are likely to be trading across multiple countries.

Some crazy stuff that the Newspapers will report Published Date : 2013-06-03 10:05:52

As a food industry we are constantly anxious about negative press coverage and the brand protection impact it can have.

The food supply chain is so diverse and global that no matter how robust our supplier quality assurance are it is a constant challenge to monitor supply chain compliance.

So we all worry about what the media will pick next, and the impact it will have on branded food or private label suppliers.

So it was with a wry smile that I noted that according to an article in the Mail, people who drink before cooking are at greater risk of causing a fire. It is estimated that 17 million people in the UK have risked starting a fire by cooking while drunk, with professional workers being the ‘biggest offenders’. It is pointed out that the risk of fire is increased when people fall asleep leaving the cooker on.

Sounds like reporting the blindingly obvious.

Delivering supply chain solutions Published Date : 2013-05-31 15:00:05

As I travelled along the A17 last week I got stuck behind a truck which has the strapline “delivering supply chain solutions” emblazoned on it.

The more I thought about it the more I felt that the respective transport company could find a better way of getting across their mission.

Here at QADEX we could easily also use this strapline yet we are a completely different business.

Many other types of business operating within the food supply chain could also say that they are “delivering supply chain solutions”

Farm assurance pays Published Date : 2013-05-29 14:49:32

Following my recent post about RSPO certified suppliers losing faith in supplier certification due to negligible benefits I read with interest that EBLEX have published some research that indicates that farm assured beef cattle typically fetched about 9p per kilo more at market than non-assured cattle in 2012, with assured lamls returning between 3p & 5p per kilo than their non-assured counterparts.

There is the business case for farm assurance

RSPO risks losing support of palm growers Published Date : 2013-05-27 14:35:59

The round table for sustainable palm oil (RSPO) runs the risk of losing Malaysian palm growers due to the increased cost of supplier certification and relatively low sales of certified palm oil resulting in the excess certified oil having to be sold as conventional oil.

This results in no premiums going to growers.

Whilst many in the industry have questioned the effectiveness of RSPO it is a worry if it falls apart as it removes a plank form an ethical compliance perspective for some in the food supply chain.

Whatever the certification scheme, in whatever part of the food supply chain it is critical that the suppliers who invest in certification are rewarded.

Supply chain risk management in the spotlight Published Date : 2013-05-24 14:27:30

Poppadoms have been in short supply in recent weeks as the 2 leading branded suppliers, Premier & Pataks and struggled to supply, despite receipe/specifications being different.

Ingredient shortages are being blamed.

Interestingly many of the companies that we work with have been starting to look at raw material availability as part of their supplier risk assessment and ensuring that food specs are looked at carefully to ensure that all ingredients have multiple sources.

Supply chain mapping is also something that may start to feature more prominently in supply chain auditing to try to identify bottlenecks and risks beyond the usual food safety risks,