In the last year there has been an explosion of articles relating to the Food Safety Modernization Act (FSMA) and the impact of FSMA on the food manufacturing industry. With several important deadlines looming in 2017, the food industry has been working hard to understand what FSMA standards mean to their businesses, and what they need to do to ensure compliance.

Food packaging has a complicated place within the standards set down by FSMA. Food packaging is not defined as “food” according to the standards outlined in FSMA, so it is not subject to all of the verification requirements for food as outlined in FSMA.

However, there is one component of the FSMA where food packaging is viewed differently. The FSMA rule on Foreign Supplier Verification Programs (FSVP) was designed to ensure that foods imported into the U.S. meet the same manufacturing standards as those manufactured in the U.S.

Under FSVP, food packaging is classified as a direct food contact substance. As such, food packaging suppliers must comply with the regulations outlined in the FSVP rule.

So what are the standards in the FSVP relating to food packaging? The FSVP requires that any supplier of food or food contact substance be able to provide a food safety plan; a corrective action plan for any issues; and a system for record-keeping. It is up to the food manufacturer to have the system in place to gather this information from its suppliers.

A third-party certification, such as an SQF designation, can be a useful tool for food manufacturers to gauge the level of compliance of their suppliers.

SQF stands for the Safe Quality Food program, a quality scheme administered the Food Marketing Institute. This particular food safety program offers three levels of certification, from primary production up to food manufacturing, distribution and agent/broker management, and it has been recognized by the Global Food Safety Initiative.

Flavorseal has received SQF Level 3 certification, the highest level of certification, which means that the company has demonstrated a comprehensive mastery of food safety and quality management systems based on the use of Hazard Analysis and Critical Control Points (HACCP) and standards developed by the International Standards Organization (ISO). This certification level also indicates that the company has developed a quality control system.

The level of record-keeping required to maintain a certification like this one provides much of the information required to verify compliance with the FSVP. The annual audit process for these certifications can provide another level of documentation that the supplier is in compliance. However, these third-party audits cannot be considered replacements for the food manufacturer’s required FSVP program. Although GFSI certifications can verify, they cannot replace a food manufacturer’s own program.

So what should food manufacturers be asking of their food packaging suppliers to prepare for the new regulations?

Your food packaging supplier should already be well on the way to ensuring their compliance with FSVP. They should be able to provide a dedicated and qualified food safety consultant that is staying informed of the necessary FSMA regulations and is ready to provide documentational support to their customers.