Corrected training information

The following is corrected training information on the FSVP module.  About 5 or 6 months ago I received a training module on Foreign Supplier Verification Program (FSVP) to teach in conjunction with the FSPCA Preventive Controls (PCAF) classes.

As you may recall there are 4 rules you need to comply with:

Preventive Controls for Animal Food
Sanitary Transportation
Foreign Supplier Verification Program (FSVP)
Accredited Third Party Certification – this is for auditors….

Over the past two years training has evolved… My first classes received PCAF only. At some point I added:

- Training I developed on Sanitary Transportation and FSVP.
- Later I updated the FSVP training to this FSPCA module.
- Then I started offering free webinars on Sanitary 
  Transportation and FSVP.
- Now the free webinars are recorded and posted 
  on my FSMA website…

Wow! So if you have not received these training please go to my website to do so…

Last week FSPCA offered a webinar to instructors to answer questions on this training module… as they say “better late than never”…. So here are some changes:

- Cooperative Agreements are in place with Australia, Canada
  and New Zealand – what I learned is that NONE of these 
  agreements apply to Animal Food (only human food). 
  This does not have a big impact because as you know if you 
  are a manufacturer in compliance with 21 CFR 507 (PCAF) 
  you deemed in compliance with FSVP to a point…

- FSVP Audits will be pre-announced for now... this is 
  primarily because of issues where Importer of Record 
  is being identified as the FSVP importer and FDA see no 
  value in showing up at a facility for a “broker”. 
  They STRESSED that all parties need that the FSVP 
  Consignee or owner has a DUNS number and that is being 
  record as the FSVP Importer.

- Inspections will be for CGMP’s and Hazard Analysis and 
  Preventive Controls OR CGMP’s and FSVP OR FSVP only. 
  You will not get an inspection for Hazard Analysis and 
  Preventive Controls AND FSVP – that would be a duplicate 

- FDA has just set up a data dash board to assist with 
  supplier verification I will be looking into this and 
  posting about it in the coming week or two.