Supply chain issues are a common concern for manufacturers even in the best business climate, but current disruptions to global supplies due to the pandemic have put an extra strain on companies. Some manufacturers have been forced to seek new partners for ingredients as those they’ve worked with before can’t guarantee availability.

The ability to be nimble when sourcing items could become a more widely accepted practice in the post-COVID-19 world as the lessons learned over the past two years have rewritten the playbook.

Food manufacturers, however, have extra responsibilities when considering these new arrangements, such as implementing effective supply chain controls.

This blog from ImEPIK will focus on your supply chain program and the steps needed to ensure your suppliers are trusted food safety partners.

FSMA and a Risk-Based Supply Chain Program

The Food Safety Modernization Act (FSMA), as outlined in Title 21, Subpart G of the Code of Federal Regulations, requires food manufacturers to employ a stricter oversight of what they are purchasing if it’s a potential hazard. That includes allergens, such as peanuts, and foods that have a history of being implicated in recalls and outbreaks of illnesses, such as leafy greens.

A company’s supply chain program must include:

  • Use of approved suppliers;
  • Determination of appropriate supplier verification activities; and
  • Conducting and documenting those activities.

If the supply-chain-applied control is from a third party, the receiving facility must verify that control through an inspection or by reviewing documentation from the supplier.

Bags of ingredients from foreign suppliersA supply chain program establishes clear steps that can be used to assess a supplier’s practices and alert a trading partner to potential food safety concerns. When properly applied, the program gives a food manufacturer — and anyone purchasing the final product — confidence that risks have been acknowledged and handled.

FSMA is designed to change food safety procedures from reacting to outbreaks to preventing them, and a supply chain program’s role is to uncover risks and identify who is controlling those risks ahead of time.

The Food and Drug Administration’s (FDA’s) Foreign Supplier Verification Program (FSVP) similarly covers imported products and ingredients.

Your Responsibilities Under a Supply Chain Program

Ensuring that your suppliers have a food safety program — and that they actually follow that program — makes good business sense. You have to protect your brand and ensure products are safe. Cutting corners when choosing whom you buy from is not sustainable.

FDA allows you to vet suppliers of raw materials and ingredients through on-site audits, product sampling, and a thorough review of their food safety records. In approving suppliers and determining verification activities, you must consider:

  • The nature of the hazard;
  • Who will be applying the controls on behalf of the supplier;
  • Supplier performance, including history and audit/test results; and
  • Storage and transportation practices.

Manufacturers can outsource supplier verification activities to a third party, and the supplier can conduct product testing and provide the information to the facility. The supplier can also submit third-party audit results as proof of verification.

ImEPIK’s Online Food Safety Training

Let ImEPIK train your Preventive Control Qualified Individual (PCQI) and food safety team on how to establish an effective supply chain program. Our 100% online course is self-paced and includes several scenarios that allow course participants to practice the verification of supply chain controls. The PCQI course also covers the FDA’s Standard Curriculum in only ten modules. ImEPIK also offers discounted rates for multiple team members, and the course is available in Spanish.

Contact us today at, via our website chat, or at +1-866-318-9855.