Meeting the Requirements of FSMA with FSSC 22000

Transcription

1 Meeting the Requirements of FSMA with FSSC Kathleen Wybourn & Jacqueline Southee 15 April 2016 Ungraded 1 DNV GL April 2016 SAFER, SMARTER, GREENER

2 Meet Today s Speakers Kathleen Wybourn Director Food & Beverage DNV GL NA Jacqueline Southee US Liaison FSSC Ungraded 2 DNV GL April 2016

3 Questions are Welcome Enter your questions in the Chat Box anytime during the presentation at the bottom right hand corner of your screen. Your questions will be answered at the end of the presentations. Ungraded 3 DNV GL April 2016

4 Meeting the Requirements of FSMA with FSSC Ungraded 4 DNV GL April 2016

5 Accredited Third Party Certification Under FSMA Ungraded 5 DNV GL April 2016

6 FDA FSMA Accredited Third-Party Certification The FDA FSMA rule on the Accredited Third-Party Certification is now final. Published November 2015, establishes a voluntary program for the accreditation of third-party certification bodies, also known as auditors, to conduct food safety audits and issue certifications of foreign facilities and the foods for humans and animals they produce. These requirements will help ensure the competence and independence of the accreditation bodies and third-party certification bodies participating in the program. Certification audits under GFSI should not be confused with Accredited Third-Party Certification under FSMA. THESE AUDITS ARE COMPLETELY DIFFERENT Ungraded 6 DNV GL April 2016

7 Foreign entities may use certifications under FSMA for 2 purposes: Certifications may be used by importers to establish eligibility for participation in the Voluntary Qualified Importer Program (VQIP), which offers expedited review and entry of food into the U.S, To prevent potentially harmful food from reaching U.S., the FDA can also require in specific circumstances that a food offered for import be accompanied by a certification from an accredited third-party certification body, In either case domestic facilities will not be audited under this program, This program only applies to foreign facilities and only under very limited cases. Ungraded 7 DNV GL April 2016

8 Accredited Third-party certification bodies Are required to perform unannounced facility audits and to notify the FDA upon discovering a condition that could cause or contribute to a serious risk to public health, Accredited third-party certification bodies must: Ensure their audit agents are competent and objective, Verify the effectiveness of corrective actions to address identified deficiencies in audited facilities, Assess and correct any problems in their own performance, Maintain and provide the FDA access to records required to be kept under the program. Ungraded 8 DNV GL April 2016

9 Two Kinds of Audits that can be performed Accredited third-party certification bodies can perform as part of the program, consultative and regulatory. In both kinds, auditors will examine compliance with applicable federal food safety requirements. A consultative audit is conducted in preparation for a regulatory audit and is for internal use. In addition to compliance with federal standards, a consultative audit also considers how the facility meets industry standards and practices. Only a regulatory audit can be the basis for certification. An accredited third-party certification body could be a foreign government or other third-party entity or individual. Ungraded 9 DNV GL April 2016

10 DNV GL A global business assurance partner Position One of the world s leading certification bodies People 2,000 highly skilled specialized employees 10,400 Food and beverage companies partner with us to ensure safety and sustainability Partnership with more than 70,000 customers in over 180 countries 80,000 Management system (ISO 9001, 14001, 18001, etc.) certificates issued under more than 80 accreditations 2,400 Healthcare organizations trust us to help them improve quality and patient safety Ungraded 10 DNV GL April 2016

11 Experience and expertise DNV GL has extensive competence and experience in auditing, and solid track record in tailoring assessment programs based on customer needs We are flexible and we work with a project management approach Ungraded 11 DNV GL April 2016

12 Meeting the Requirements of FSMA with FSSC Jacqueline Southee. US Liaison, FSSC 22000

13 Current Issues for the Food Industry Evolving Consumer demands Changing demographics Complex supply chain Emerging threats Advancing technology Changing Legislation Does GFSI meet the requirements of FSMA?

14 GFSI and Private Certification Developed to protect private brands and ensure confidence in the production of safe food Global collaboration and capacity building Guidance document Defines minimum safety requirements for benchmarking 11 recognized schemes Certificates worldwide

15 GFSI recognition Business to Business recognition Global harmonization Certified once, accepted everywhere Increases customer satisfaction and improves trade Reduces costs and facilitate exports

16 Food Safety Modernization Act, 2011 FSMA Necessary update of GMPs and old legislation Move to be preventive rather than reactive Months of consultation with private sector Publication of Final Rules from Sept 2015

17 Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventive Controls for Human Food Published Sept 2015 Implementation Sept 2016 Preventive Controls US-Centric but with far reaching influences Focus on Supply chain

18 Preventive Controls: Defines a management system approach Flexibility with accountability Requires HARPC Training is a legislative requirement Focus on the Supply Chain Demand for the verification of suppliers Foreign Supplier Verification

19 Does GFSI Certification = Compliance? Preamble to PC Rule: where systems mirror the requirements, existing records can be used to provide evidence of compliance (Comment 8) Systems could be used to provide. evidence of compliance with the appropriate supplements (Comment 382) Prior to this report, the FDA believed it premature to accept the schemes, but that once evidence of alignment was provided it is suggested that systems could be used as;. evidence of validation (Comment 496),. verification of supplier (Comment 673),. to meet the requirements of the annual audit required for FSVP (Comment 683) Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventive Controls for Human Food

20 FSSC versus FSMA Shared goals of food safety through preventive controls and flexible management system approach FSSC comprised of 3 elements ISO Prerequisite Programs (PRP s) Additional requirements Gap analysis commissioned

21 Comparison of FSSC against the P C for Human Food (Final Rule) Key areas FDA Preventive Controls Food Safety Plan FDA GMPs (117 Subpart B) FSSC Scheme Equivalence 1. Overarching Policy Statement No No Yes (Exceeds) 1. Written Plan Yes No Yes (Comparable) 1. Experienced Individual in Charge Yes No Yes (Comparable in qualifications; Exceeds in responsibility) 1. Trained Staff Yes Yes Yes (Comparable) 1. Prerequisite Programs No Yes Yes (Exceeds) 1. Raw Material/ Incoming Product No No Yes (Exceeds) Safety Assurance 1. Supplier Verification Yes No Yes (Comparable) 1. Allergen Management Yes Yes Yes (Comparable) 1. Validation of Controls Yes No Yes (Comparable) 1. Finished Product Testing No No Yes (Exceeds) 1. Sanitation Control Yes Yes Yes (Exceeds) 1. Corrective Actions Yes No Yes (Comparable) 1. Traceability No 1 No Yes (Comparable) 1. Recall Yes No Yes (Comparable) 1. Record Retention Yes No Yes (Different) 1. Food Defense No 2 No Yes (Exceeds) 1. Internal Audit & Management Review No 3 No Yes (Exceeds)

22 FSSC versus FSMA In summary the report states of FSSC 22000; it s required elements exceed the rule in several areas. Where it is not exceeding, measure comparable to the Final Rule requirements. There are no elements of the FDA preventive control and cgmp requirements that are clearly just missing in FSSC that we could determine...

23 Exceeds: FSSC vs FSMA Raw material/ incoming product safety assurance: Exceeds Finished Product Testing: Exceeds Sanitation Control: Exceeds Food defense: Exceeds Internal audits and management review: Exceeds

24 Comparable FSSC vs FSMA Supplier verification: Comparable Allergen Management: Comparable Validation of Controls: Comparable Corrective Actions: Comparable Traceability: Comparable Recall: Comparable

25 Different FSSC vs FSMA Record retention: Different Terminology HACCP and operational PRPs vs Preventive Controls Food safety team leader vs Preventive Controls Qualified Individual Withdrawal vs Recall

26 FSSC certified = FSMA compliant? Side by side comparison Cooperation with FDA and Industry Share with experience and knowledge Develop confidence of FDA, Auditors and Inspectors

27 Mission of FSSC To be the world s leading, independent, GFSI recognized, ISO based food safety and quality management system for the entire food supply chain.

28 Global organizations using FSSC 22000

29 11,000+ certificates worldwide 11,000 Sites 107 Licensed CBs Certificates in 154 countries 1500 auditors

30 Issued certificates (November 2015)

31 Benefits of FSSC Management System framework Visibility throughout the food chain In depth audits conducted, consistent and systematic Three year cycle with annual surveillance audit Internal audit program Training programs reviewed Audit ready all the time! Consistency, Communication and Compliance

32 The Entire Food Supply Chain ISO 22000: Food safety management systems ISO/TS 22003:2013 -Requirements for bodies providing audit

33 Integrity Program Procedure for CB to become licensed for FSSC Scopes - checks on issued certificates Desk reviews - checks on (surveillance) audits Auditor database screening KPI monitoring (database Audit Data Summaries) Program for CB office audits Witness audits - Program for announced but unscheduled audits of certified organizations

34 Alignment of FSSC with FSMA Contribute to global food safety Extend resources of FDA Provide supplier verification Provide FSVP audits Provide Risk assessment of companies Continuous improvement by data sharing

35 Let s connect Website jsouthee@fssc22000.com Phone LinkedIn Group FSSC 22000

36 We thank you for your participation today Kathleen Wybourn Director Food & Beverage DNV GL Jacqueline Southee US Liaison FSSC Ungraded 36 DNV GL April 2016

37 CONTACT US: Jacqueline Southee, US Liaison FSSC Kathleen Wybourn, Director Food & Beverage, DNV GL April Lefebvre, BDR Food & Beverage, DNV GL Ungraded 37 DNV GL April 2016

38 Next DNV GL & FSSC Webinar April 29 th Register now for DNV GL Food Safety Symposium September 21 st and 22 nd Rosemont, IL Ungraded 38 DNV GL April 2016