Jan 28, 2014

FMI Comments Based on Two Proposed Rules: Foreign Supplier Verification and Third Party Auditors

January 28, 2014 – ARLINGTON, VA –  Food Marketing Institute (FMI) last night submitted comments to the U.S. Food and Drug Administration (FDA) in support of its ongoing pursuit to help enhance public health and strengthen the nation’s food safety regulatory system.

FMI prepared and issued comments on two FDA-proposed rules: The Foreign Supplier Verification Programs for Importers of Food for Humans and Animals and Accreditation of Third-Party Auditors/Certification Bodies to Conduct Food Safety Audits and to Issue Certifications proposed rules.

FMI expressed strong support for annual onsite audits for the most serious food safety hazards controlled by foreign suppliers in the Foreign Supplier Verification proposed rule.  FMI urged FDA to allow for audits conducted pursuant to existing global food safety standards, such as those benchmarked by the Global Food Safety Initiative, to satisfy foreign supplier verification requirements.

FMI also requested clarification on the term “importer” since it differs from the definition of “importer of record” and requested that FDA take into consideration how this rule will work with other rules being developed, such as hazard analysis and preventive controls and sanitary transportation. 

In comments on the Accreditation of Third Party Auditors Rule, FMI encouraged the agency to focus auditor notifications to FDA on the most serious food safety deficiencies, and grant auditors flexibility to conduct audits both within and outside of the scope of FDA’s accreditation program.  

FMI Vice President and Chief Regulatory Counsel Erik Lieberman offered the following statement: “There is simply no substitute for onsite audits in assessing the food safety practices of suppliers.  We believe that FDA has the opportunity to greatly enhance food safety practices by requiring onsite audits in the Foreign Supplier Verification rule, and strongly urge the agency to do so.”


FMI’s full comments can be accessed on FMI.org:
• Foreign Supplier Verification Programs for Importers of Food for Humans and Animals
• Accreditation of Third-Party Auditors/Certification Bodies to Conduct Food Safety Audits and to Issue Certifications