Time to review your foreign supplier (FSVP) program?

FSMA FSVP FDA 2019

The FSVP regulation requires importers to perform certain risk-based activities to verify that human or animal food they import into the United States has been produced in a manner that meets applicable U.S. food safety standards.

Recently I have noticed several FDA Warning Letters for FSVP inspections.  FDA appears now to be conducting FSVP-specific inspections, for example, in one letter they state:

On June 28, 2019, the Food and Drug Administration conducted a Foreign Supplier Verification Program (FSVP) inspection at your facility….This inspection was conducted to determine compliance with the requirements of section 805 of the Federal Food, Drug and Cosmetic Act (FD&C Act) (21 U.S.C. 384a) and the Foreign Supplier Verification Program (FSVP) implementing regulation in 21 CFR part 1 subpart L.

and, notably:

At the conclusion of the inspection our investigator provided you with a Form FDA 483a, FSVP Observations.”

There seems to be a specific Form 483a which is used for these inspections.  However, a search at FDA.gov did not yield a example of this form. For calendar year 2019, I found 315 citations in FDA’s citations database for failure to develop Foreign Supplier Verification Programs.

See the full-resolution chart of 2019 FDA 21 CFR Part One citations (includes FSVP inspections) [PDF]: https://www.marianboardley.com/charts/21%20cfr%201.pdf

If you import ingredients, dietary supplements or foods, 2020 might be a good time to get your foreign supplier verification program on track, or take FSVP training!