Intentional Adulteration
This rule outlines risk-reducing strategies to prevent intentional adulteration from acts intended to cause wide-scale
public health harm and requires, for the first time, a food defense plan. This applies to facilities including non-farm
almond handlers and non-farm huller/shellers and the next compliance deadline is July 26, 2019 for large businesses.
Foreign Supplier Verification Program
This rule requires importers to verify that their
foreign suppliers have adequate programs in
place to ensure the food coming into the U.S.
meets food safety standards comparable
to those in the U.S. This applies to almond
handlers that import ingredients directly from
a foreign supplier (you are exempt from this
rule if you purchase ingredients from a U.S.
supplier). Compliance of this rule began back
in May, 2017 for all businesses.
Learn more in the FSMA Fact Sheets on the
website:
• How do I Comply with Supplier
Verification Requirements
?
Accredited Third-Party Certification
This rule establishes a voluntary program for
the accreditation of third-party certification
bodies/auditors to conduct food safety audits
and issue certifications outside the U.S.; it
would only apply in two situations, neither
of which affect the U.S. almond industry: 1)
if you’re trying to be part of FDA’s Voluntary
Qualified Importer Program or 2) if you’re
importing food from a country for which FDA
requires certification as a condition of import.
You can find all the factsheets listed
above at almonds.com/growers/FSMA
or almonds.com/processors/FSMA.
ABC utilized input from Elizabeth Fawell
and Maile Hermida, lawyers with Hogan
Lovells US LLP in Washington, D.C. in the
preparation of this article. The article is
provided for informational purposes only
and does not constitute legal advice.
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