Issue link: https://read.dmtmag.com/i/1034837
52 STiR coffee and tea / Issue 5, 2018 (October / November) Spoils: Foreign Supplier Verification Advisory The government of Uganda this fall took the unusual step of ordering the closure of 95 coffee processing factories in the Kayunga District – a response to concerns that rain-damaged coffee could result in export bans. Victor Yawe, quality control officer at the Uganda Coffee Development Authority said all factories built with timber and iron sheets and those built in wetlands "pose a risk of contamination." The impact of this news item may seem distant but the foreign supplier verification pro- gram (FSVP) is now law for the largest US companies and in March 2019 will include all firms earning $1 million or less. Every US commercial import exceeding $2,500 must be recorded in the automated commercial environment/international trade data system (ACE/ITDS) data- base. FDA is only beginning to enforce the new law, which empowers FDA to take proactive steps to prevent the sale, distribution, and consumption of tainted food products. Uganda and all other coffee, spice, and tea suppliers are wise to take precautions now. FSVP compliance "At origin, there are relatively inexpensive ways to reliably and accurately measure brix, moisture, and water activity. Depending on their level of engagement, roasters may choose to partner with producers directly to manage quality and monitor possible contamination," advises Spencer Turer, v.p. at Coffee Enterprises in Hinesburg, Vermont. "FDA requires importers perform certain risk-based activities to verify that coffee and tea imported into the US has been produced in a manner that meets applicable US safety stan- dards," Turer explains. FDA's preventative controls for human food specifies that a trained PCQI (preventive controls qualified individual) develop and apply a food safety plan – mean- ing roasters shall use a PCQI to determine their level of risk and develop a plan that includes hazard analysis (biological, chemical, and physical hazards). Preventatives controls include process controls, food allergen controls, and sanitation. Lastly, roasters are required to have a comprehensive recall plan, he said. The key to compliance is the individual identified as the FSVP importer. This cannot be a company. It must be an individual responsible for the FSVP plan. It could be an employee charged with food safety, a hired broker or an independent importer reselling the products. Regardless of affiliation, that individual must own the product at the time of entry. It is manda- tory this individual create a FSVP plan and keep any foreign suppliers in compliance. A lot of companies do not want the respon- sibility of making sure the arriving food prod- ucts are safe. In these instances they need to let someone else import it so that the product is already in the US before they buy it. Export concerns And it is not just exports to the US that are getting additional scrutiny. In January Pakistan adopted more stringent testing for aflatoxins, a group of metabolites from Aspergillus fungi that is commonly seen in grains and tea. These toxins can prove fatal so when a shipment of tea from Kenya was discovered to contain aflatoxin, Pakistan required all imports to be tested. Exports plummeted from more than 24 million to 12 million kilos and sales dropped by half. A compromise on thresholds led to the re- sumption of imports. FDA recognizes the enormity of the task and has enlisted organizations to assist companies in complying. In August, the American National Standards Institute (ANSI), coordinator of the US voluntary standardization system, accredited the first third-party certification body recognized un- der FSMA. A release states that ANSI accreditation supports those seeking FSMA compliance with the foreign supplier verification program and predicted many more food safety spe- cialists will be certified. By Dan Bolton Incidents of water damage leading to potentially fungus-tainted coffee are not limited to overseas. These examples all show coffee damaged in US coffee warehouses.

