STiR coffee and tea magazine

STiR coffee and tea 47 FSMA Basics The Food Safety Modernization Act (FSMA) passed the United States congress and signed into law by President Barack Obama in 2011 and reflects a shift in the government's effort toward food safety. Instead of looking for problems with raw food imports, FSMA calls on import compa- nies to track how food is processed and transport- ed by exporters before it arrives on US soil. The goal, the Food and Drug Administration explains, is to prevent the potential for food con- tamination and minimize food recalls in the Ameri- can supply chain. To do this, all food facilities covered by the new law must conduct hazard analysis and risk- based preventive controls (HARPC) and imple- ment what the government calls "science-based preventive control measures" to reduce the risk of contamination. FSMA calls on food processors to do two things. First companies must understand how HARPC works and differs from the hazard analy- sis and critical control point (HACCP) that many companies currently have in place. HARPC and HACCP are food safety management systems in which raw food products are analyzed for biologi- cal, chemical, or physical hazards during produc- tion, procurement, handling, manufacturing, distri- bution, and eventually consumption. Second, companies must increase their vigi- lance by incorporating HARPC into their opera- tions. HARPC is much like HACCP yet it focuses on preventive measures to identify and eliminate potential risks to the food supply. Under HARPC, companies must establish and implement science- centered risk-based preventive controls, which extend beyond the critical control points (CCP) required by HACCP. "Facilities that are doing less than a $1 mil- lion in global sales have an exemption from the HARPC plan," said Bracey Parr, a regulatory spe- cialist for Registrar Corp. and an expert on the new law. "What the FDA is thinking is this: If a company is doing a million dollars in sales, they have the resources to do this and their products are being consumed by a large number of people. Very, very small importers have exemptions because this is a burden. FDA does try to take that into account." About 48 million Americans, or one in six, be- come sick by foodborne illnesses each year, FDA reports. Nearly 130,000 require hospitalization and 3,000 people die. The new law targets im- ported raw foods, in part, because 15% of the US food supply arrives from other countries and new hazards are being discovered in foods each year. For complete information on the Food Safety & Modernization Act, visit the US Food and Drug Administration's website: http://bit.ly/2ubxwKp "We have been prepping our suppliers as soon as this law came into effect in 2011. We have been sending them forms and doing document audits every year," said Sherine Kanagasunderam, quality assurance manager for QTrade Teas & Herbs in Cerritos, Calif. Under the law, FDA is required to implement new food safety regulations that focus on proactive measures to prevent the potential for contamination of food across the supply chain. All food facilities that are affected by FSMA must institute hazard analysis and risk-based preventive controls (HARPC) and use "science-based preventive control measures to reduce the risk of food contami- nation," according to FDA. "There are two parts of the act," said Parr, who has actively advised the coffee industry on the law and its impacts. "HARPC is an update to HACCP (Hazard Analysis and Critical Control Points). There's a big integration of scientific litera- ture and knowledge about food safety especially looking at the supply chain. It's really important that there's transparency in the supply chain to make sure foreign supplies are living up the requirements." The process begins with the foreign supplier verification program (FSVP) that requires importers in the United States to make sure suppliers are providing the same level of health protection as domestic suppliers and that they are com- plying with regulations. "Importers have to take a good, hard look at the supply chain," Parr said. "What is the inherent hazard associated with the food? What is the supplier's his- tory or rap sheet, so to speak, with FDA? Everything FDA is risk based." "You have to go out and verify that all hazards are addressed at the foreign facility," Parr said. "Then the importer has to verify (that any issues are being addressed)." Impact on the coffee importers "Any coffee facility that's registered (as an importer) needs to look at their food documentation and make sure it meets HARPC standards – packing size, ag- gregators, decaffeination plants. Everyone needs to do an analysis," Parr said. "If FDA inspects, they want to see that you've done the work to make sure you're exempt." Generally, coffee hazards are controlled in the roasting process but pes- ticide residues can be a problem, Parr said. Then there are physical hazards such as dirt, pebbles and other impurities among the green beans. "If the facility doesn't have the ability (to remove physical hazards), they have to make it clear in their plan that hazards will be controlled down the way," Parr said. "The law is pretty flexible in that regard. They just want to see that you've done the work and it would need to be explicitly written in both (the export and import) plans." Impact on tea importers Tea importers face the same requirements. While most coffee's food safety con- cerns are ultimately eliminated in the heat of a roaster, processed tea leaves re- main susceptible and require a close eye. Two importers contacted for this article report exporters are prepared to meet US government expectations. "I understand the atmosphere in the industry is probably (that) the US import- ers are concerned about their regular suppliers in terms of compliance and the exporters are panicking about the rules or regulation. I thought about the same, actually," said Shengyuan Chen, executive director of Firsd Tea North America, LLC. "But after I talked to several people in China, the reality is much better than I thought. There are very few tea factories in China that are not certified by food safety systems, so for them, what FSMA and FSVP require is probably a bit more documentation work. "For those who are not certified by third-party auditors, I can't speak for them and I don't think they are all unqualified, but as long as they keep a track of each step they do truthfully, they will still be considered as compliant," she said. Zheijing Trading Co., parent company to Firsd Tea, exports more than 115 million pounds of tea each year from China. Firsd Tea imports another 450,000 pounds a year from other Chinese suppliers. And whether the tea comes from the

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