You got your cup of coffee. You are reading your emails and alerts this morning. You see that the FDA has issued warning letters to a number of companies. These alerts were for violations in their HACCP plans. Huh, the companies are operating with issues in their food safety hazard prevention programs. The FDA will give them a week or so to provide information that illustrates the companies will do better in the future. You double check to see if your morning snack is on the alert listing. Hopefully, that will not be the extent of your Supply Chain risk review.
Do you have a relationship with the companies? Have you received any products from them prior to the FDA warning letters? Were you depending upon these companies preventing a hazard for the products that they supply to you?
Were any of the products provided to your ingredient suppliers for further processing? Are they prepared to manage an unexpected hazard?
With the Preventive Measure for Human Foods, you would expect to be notified of any potential uncontrolled risks that may be present in products supplied to you. This notification should not be limited to just the initial communication when you receive a new product from a partner.
You need to think about who is watching the potential risks to the supply chain. Share-ifyer, you can check your supply chain management program on Share-ify. You double check your partners’ preventive control documents on Share-ify. Using your contact platform, You immediately request information to clarify the risk situation within the supply chain.
Remember your supply chain management program is only as good as the data. If you embrace the “one up and one down” philosophy, you may fail. The source of the product affected by the FDA notification letters may be one, two or even three links outside of your supply chain traceability. You should deploy a program that traces documentation through the supply chain to where the products are actually manufactured. You could use your partners to provide you with initial and ongoing compliance documentation.
Just because the FDA identified the importer of record in the alert. It does not mean, that the source companies are not using other importers.
What are you going to do with your information regarding the FDA alerts? You may change their status to discontinued, disapproved, probationary, or just do nothing. You could utilize your Risk Matrix to “color highlight” the partner’s risk level. You could notify your food safety manager or factories.
Then again, are you managing your supply chain or waiting for someone else to call you? The sooner you identify and mitigate the risk, the less exposure you and your customers to the implications of food safety failures.
Share-ifyers, manage your risk, Share-ify
One last thought, what if the companies that got the notification letters instead passed the FDA review of their food safety program? Then the next week, they got notification letters due to findings of drugs or pathogens or both on their products? Enjoy your coffee and snack.
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