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How Packaging Suppliers Can Help Processors Comply with FSMA

It’s not every day a food industry supplier achieves SQF compliance, but Flavorseal was proud to achieve its fourth annual Safe Quality Foods Level 3 certification in April 2017. This also marked the third year running the company has received SQF Level 3 with an  “Excellent” rating, currently the highest SQF rating awarded.

Flavorseal’s Dr. Gus Eskamani, an SQF practitioner, played a key role in this achievement. Corporate chief science and compliance officer for the company, Eskamani also holds the coveted PCQI designation (meaning he’s a Preventive Control Qualified Individual). In this role, Eskamani ensures that Flavorseal is in compliance with all requirements of the Food Safety Modernization Act (FSMA). He’s also able to answer specific questions for customers relating to Flavorseal’s packaging or process and its own FSMA efforts.

Here, Eskamani shares some of the back story on the Food Safety Modernization Act when it comes to packaging, why achieving a third-party certification like SQF is beneficial for suppliers like Flavorseal, and how this helps protein processors achieve compliance.

Q: How did the Food Safety Modernization Act change processing and/or documentation requirements?

A: The requirements of the Food Safety Modernization Act are basically tied to one goal: controlling the hazards associated with foods and beverages sold in the United States.

What’s unique about the legislation is that it spells out, for the first time, how supply chain stakeholders linked to a certain product can share responsibility for controlling the hazards associated with producing the food product or ingredient. Ultimately, the law says food safety hazards must be addressed and documented, whether it’s done by the supplier, the converter, or the manufacturer of that product.

The FSMA also describes how this needs to happen: Members of the supply chain linked to a specific food or beverage product have to analyze the safety hazards and then implement a food safety plan to manage those hazards with risk-based preventive controls. They also must verify the controls are effective and validate that the controls consistently work. Finally, these stakeholders have to document the entire process for transparency and traceability.

Each entity within the product’s supply chain can take care of certifying that its product’s or process’s hazards have been assessed, controlled and addressed. But if a supplier or processor in the chain doesn’t do its part, addressing those hazards falls to the next member of the supply chain, which also must address the hazards associated with its own process. As you can see, suppliers and processors who assess and manage the risks involved in their processes provide distinct advantages for their customers further down the supply chain.

Q: What are the common questions you receive from clients and prospective customers when it comes to FSMA requirements and deadlines and how do you address them?

A: The No. 1 question we get is “how are you managing risk?” And we use a variety of processes and documentation to answer this question for our customers. We work with our customers to provide the documentation they need for their own reporting purposes, to supplement their own reporting. Our SQF certificate, for example, can fulfill some documentation needs.

Q: How are packaging products and imported products treated under the Food Safety Modernization Act?

A: Packaging that comes into contact with food, such as film and netting, is included under FSMA. This means that hazards from packaging that comes in contact with food have to be assessed, generally by both the packaging supplier and by the processor using that packaging to package a specific product.

Packaging suppliers like Flavorseal can help with these assessments by providing needed documentation upon request. All of this information can become part of the processor’s own hazard management process.

Meanwhile imported products, such as imported film for packaging, are covered by a subsection of FSMA referred to as the Foreign Supplier Verification Program. As with FSMA, this program is intended to understand and control supply chain risks from imported products to provide transparency, visibility and traceability.

FSVP is a very comprehensive program covering practically all aspects of imported products and includes steps such as hazard analysis, evaluation of food risk and supplier performance, supplier verification, corrective actions, and re-evaluation of supplier performance. Once again, the importer or buyer needs to receive audit records, lab test results, surveys, questionnaires, and certifications to verify that hazards have been assessed, managed, controlled and documented. If these documents are not available, buyers can audit foreign suppliers themselves.

It’s important to note that not just anyone can prepare this documentation: Both FSMA and FSVP programs need be created, verified and validated by an individual holding the PCQI designation.

Q: What key deadlines apply to the Food Safety Modernization Act?

A: Flavorseal works with several customer size categories, and these require specific approaches. Many of our customers are large processing corporations (employing more than 500 people), which had to reach FSMA compliance in 2016. Medium- to small-sized companies (employing 500 or less) need to reach compliance by September 2017. And very small enterprises, generally defined as those with less than $1,000,000 in sales, are required to achieve compliance by early 2018.

Flavorseal is considered a medium-sized entity, but we took a proactive role and achieved our FSMA compliance in 2016, one year earlier than required. This way we were able to provide our customers with all relevant data including supplier surveys, questionnaires, specifications and food safety documents such as Hazard Analysis Critical Control Points (HACCP) and Hazard Analysis Risk-based Preventive Controls (HARPC).

Q: How long does it take food processors on average to achieve FSMA compliance?

A: It depends on the size of the company, the complexity of the process, and the level of risk associated with the product. For a medium-sized company, it is expected to take three to six months to be in compliance if the company already holds a third-party safety scheme certification. If not, the process may take longer.

Q: How does choosing a supplier with an SQF designation help processors meet FSMA requirements?

A: The SQF program, which is managed by the Food Marketing Initiative, is one of a number of voluntary food safety and quality schemes companies can adopt that are recognized by the Global Food Safety Initiative (GFSI). Other commonly used GFSI schemes include the British Retail Consortium (BRC), and Food Safety System Certification 22000 (FSSC 22000).

Choosing suppliers certified under one of these programs gives processors and manufacturers a higher level confidence about their converters and vendors, because these programs are designed to improve food safety throughout the supply chain. As such, they have some of the same requirements as FSMA and can assist companies in preparing and meeting their FSMA requirements. However, there are some elements of FSMA that go beyond these schemes and may require additional documentation. This additional information can be secured through an on-site audit.

Q: What are the specific FSMA packaging requirements under which some processors may be most at risk or where they may need to make changes?

A: Processors need to identify the product risk classification for each packaging application. This is determined by conducting a risk analysis (either HACCP or HARPC) to determine the extent of FSMA requirements they are subject to when it comes to having a food safety plan, as well as programs dealing with allergens, sanitation, recalls, food fraud, food defense, and supply chain programs.


Ensuring food safety and quality in packaging is one of a number of issues protein processors face today. For additional insights on maximizing efficiency, incorporating advancements and reducing waste, request our free guide:





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