Together, these closely interconnected requirements –preventive controls for facilities and farms and importer verification that imported food meets U.S. standards – establish the central core of the regulatory framework envisioned by FSMA. The four proposed rules establishing this framework are in the final stages of review and should be published for public comment in the next several weeks.
Accredited Third Party Certification
The fifth rule we have prioritized in implementing FSMA addresses accredited third-party certification, which is a central example of FSMA’s focus on public-private collaboration.
The Foreign Supplier Verification Program makes private sector supply chain management the foundation of the import safety system, but Congress has also recognized the important role already being played in supply chain management by private sector third-party audits and certifications. Like GFSI, Congress and FDA know that rigorous, objective private audits can add significant food safety value and thereby complement oversight by public regulators. But we also recognize that rigor and objectivity cannot be taken for granted.
That, of course, is part of the motivation for the pioneering work GFSI has done to strengthen the private audit system. And Congress has given FDA a mandate to build on this work by establishing an Accredited Third-Party Certification Program.
Under this program, FDA will recognize accrediting bodies and set standards for accreditation of third-party certification bodies and auditors aimed at ensuring the rigor, objectivity and, most importantly, the transparency of third-party audits. Transparency means that the results of audits for certification will be available to FDA, which in turn means that we can both assess the rigor of private audits and rely on them as part of the public system of assurances and accountability for food safety.
The Accredited Third-Party Certification Program is central to FDA’s vision of a system that provides significantly elevated assurances about the safety of food moving in international trade in a more efficient way. We think a framework that enhances the public credibility of third-party audits can both help satisfy FSMA’s foreign supplier verification requirements and contribute to streamlining the current private audit system.
We all know about the distractions and costs involved when a single facility is subject to multiple, often redundant audits. In our complex food system, there will likely continue to be demands on suppliers for audits coming from different directions and for different purposes.