By: Heather Williams
In the United States, we take for granted the safety requirements put on our industries – whether it be for employment, services, medicine, or even the foods we eat. As more and more recalls are hitting the news, we are becoming more and more concerned when it comes to food safety. And that concern is warranted!
This risk, however, has not stopped Americans from being interested in foreign food. According to the Centers for Disease Control and Prevention journal Emerging Infectious Disease, the article “Outbreaks of Disease Associated with Food Imported into the United States 1996 – 2014” we are importing food more than ever. According to the article, 19 percent of the food American’s consume is now imported. Most of which includes fish and shellfish (with 97 percent being imported), followed by fresh fruits of which 50 percent is imported, and fresh vegetables of which 20 percent is imported. According to the article, “the proportion of food that is imported has increased steadily over the past 20 years because of changing consumer demand for a wider selection of food products and increasing demand for produce items year round.” People want food and ingredients not native to the US or not in current local season. This increased demand has lead to a dramatic increase in importing those foods. According to researchers from the “Outbreaks” article, “the proportion of food that is imported has increased steadily over the past 20 years because of changing consumer demand for a wider selection of food products and increasing demand for produce items year round.”
The problem with sourcing food from other countries stems from sanitation and food safety practices vary from one place to another. Where one country may refrigerate a particular item, another commonly leaves it at room temperature. Packaging and labeling are not universal across the globe, so different information that is important for one country is absent on the label in others. Some countries are more prone to disease contamination of food than others.
During the study period of 1996 to 2014, there were 195 outbreak investigations where imported food was implicated. This resulted in 10,685 illnesses, 1,017 hospitalizations, and 19 deaths. This rate continues to increase with the trend of increased imported foods. During 1996 to 2000, only three imported food related outbreaks were reported compared to 18 per year on average from 2009 to 2014.
The United States Food and Drug Administration (FDA) has passed a rule in the Food Safety Modernization Act (FSMA) that provides specific requirements for importers of food for humans and animals. This Act and Rule is designed to make food imported into the United States maintain the same standards as those produced inside the United States.
Food Safety Modernization Act (FSMA)
Signed into law on January 4, 2011 by President Obama, the FDA Food Safety Modernization Act (or FSMA) was one of the most significant updates reforming food safety laws in more than 70 years. This Act helps to ensure that the United States food supply is safe, regardless of where the food comes from. The primary tenant of the Act is the shift of focus from the current situation of responding to when things go wrong to putting measures in place to prevent things from going wrong.
These new regulations put systems into place to create acceptable practices for transporting, producing, labeling, and importing foods. Considering the increase in food related illness in correlation with increased food importing, and the higher instances of food related illness with imported food compared to domestic food, a major aspect of the FSMA is regulation of imported goods.
Foreign Supplier Verification Programs
The Foreign Supplier Verification Program is a large part of the FSMA. This FDA rule for importers of food for humans and animals was first proposed as part of the FMSA in July 2013 with compliance dates beginning May 30, 2017.
The Foreign Supplier Verification Program (FSVP) requires importers to verify that their foreign suppliers are maintaining the same practices. This is to ensure food is produced at the same public health protection and preventative measures as those outlined in the program and that are observed by producers within the United States.
For each item imported from each supplier, a FSVP must be drafted. Each item is assigned a Unique Facility Identifier (UFI) that must be used for each line entry of food product that will be offered for importation into the United States. There is a process by which importers will acquire these numbers so that Verification Programs can be traced and monitored.
Some of the factors that must be included in the FSVP include a risk assessment to determine known or reasonably foreseeable hazards associated with the food. For example, if the food contains an allergen the risk could be that the allergen would not be properly labeled. If the food requires a temperature control to maintain safety, there is a risk associated with that. Additional factors in the risk assessment include an evaluation of the foreign suppliers past performance and a hazard analysis of the supplier. The importer is now required to conduct supplier verification activities, such as a site visit or interviews to find out how food is processed and handled. The importer must also conduct corrective actions when things fall outside of the approved activities. According to the Act, this risk assessment must be reevaluated at a minimum every three years or as new information becomes available about a potential hazard or performance of the foreign supplier.
The risk assessment includes a Hazard Analysis, which assesses the likelihood that hazards could occur in the absence of safety and production controls and what illness or injury may occur as a result. Factors considered in the Hazard Analysis include: (1) formulation of the food, raw materials, and ingredients used to make the foods, (2) procedures for harvesting, raising, manufacturing, processing, and packaging foods, (3) sanitation and employee hygiene requirements, (4) packaging and labeling activities, and more.
The FSVP includes corrective action measures for when a foreign supplier becomes non-compliant with the Verification Program. The importer must promptly take action to either discontinue use of the foreign supplier until they become compliant or other appropriate action depending on the circumstances.
While you enjoy your imported breads, cheese, crackers, fish, and produce, know that the FDA is taking measures to keep you safe. It is still up to each individual to use caution with food choices to maintain our own health and safety, as no Program is perfect or perfectly enforced. But, thankfully, more is being done to help ensure our safety.