Assessing Your Readiness State for FSMA: Stabilize, Then Benchmark
I find that the FSMA readiness of major food brands and CPGs runs the gamut from “scrambling” to “got it covered” — and everywhere in between. Smaller companies have been given more time to prepare by the FDA. Larger companies have considerably less runway to get ready.
Whether supplier vetting is being driven by procurement or quality assurance, one challenge is almost universal: The globalization of supply chains compounded by M&A activity means that there are thousands of far-flung suppliers to assess.
Not knowing where inspector reports are or how to prioritize your contact with suppliers is a recipe for chaos. Enterprise IT folks know that:
- You can’t be blind to environment data; you need it all in one place
- Once you have it all in one place, you need a way to quickly separate the high-priority problems from day-to-day environment noise, or else you’ll go crazy!
While this varies highly depending on the level of organizational maturity, we think of this as a two-step dance…
As consolidation brings new suppliers into the family, having a potentially problematic 483 sitting on someone’s laptop or stuck in a drawer 2,000 miles away is no help at all. The first question to answer is, “How can I quickly find out what’s going on across our thousands of suppliers? And maybe even their suppliers?”
29% of inspections yield a 483 for all food and cosmetic companies who get an inspector visit. Staying on top of this means having a complete FDA inspection history of your entire supply chain (preferably auto-updated each month) in one place, at your fingertips — not stuck in a drawer or on a random server somewhere.
This “single version of the truth” does more than save your staff tons of time they would otherwise spend chasing down inspection data. It sets the stage for fruitful best practices in compliance, quality and risk management.
Benchmarking Yourself Against Industry and Competitors
One of our clients (a global food CPG) then took the reporting and data a step further by establishing a benchmarking program. By being able to see, search and compile all inspection-related documentation in their network, our friend was able to:
- See which suppliers were getting “dinged” by inspectors at a higher rate, which helped her better prioritize her staff’s activity.
- Use this data to establish her company’s benchmarks against key competitors and the industry at large; this gave her the credibility to ask senior leadership for the resources her department needed to monitor and remediate problem suppliers.
This could help anyone build better practices right into a company’s supply chain program — and lets suppliers know that you know what’s going on, which will encourage them to police themselves better going forward.
How would you rate your readiness on the “scrambling” to “got it covered” spectrum? We always love discussing granular challenges and discovering new perspectives. Reach out for a conversation any time!
For more info on FDAzilla can help you with your FSMA/Food Safety Needs, click here or email me at tony@FDAzilla.com