Ken Odza, Corporate Counsel, Food Safety Kellogg Company What’s Theirs is Yours: Assessing Suppliers’ Compliance & Co-Packers’ Responsibilities Ken Odza, Corporate Counsel, Food Safety Kellogg Company
Disclaimer The views presented here are my own, and I am not presenting on behalf of my employer. This presentation is for informational purposes only. Nothing in this presentation should be construed as providing legal advice. Your participation does not create an attorney-client relationship. You should consult with your counsel concerning compliance with the Food Safety Modernization Act.
Challenges 2. Solutions
Challenge 1: Preventing Supplier Recalls
Challenge 1: Preventing Supplier Recalls
Challenge 1: Preventing Supplier Recalls
Challenge 2: FSMA Supplier Verification Linear
Challenge 2: FSMA Supplier Verification Document Heavy Linear
Challenge 3: Brand Protection
How Can Your Supplier Program Meet All Three Challenges? Sometimes your program works simultaneously to prevent recalls, comply with regulations and protect brand but not always . . .
Kellogg Global Supplier Approval Process (New Ingredient and/or New Supplier Site) Assess Supplier’s QMS Define expectations Identify and mitigate risks - Conduct hazard analysis Document Commitments, Hold suppliers accountable Raw Material Information Sheet (RMIS) GFSI Audit Kellogg Supplier Quality Requirements (KSQR) Food Safety Assessment Nutrition Assessment Kellogg Supplier Audit Specifications Signed by Supplier Signed Contract Ongoing Supplier Reviews Risk Based Audit Strategy Key Assessments: Allergen review RM supply chain Country of origin Certifications GFSI audit review Kellogg audit Lethality assessment Ingredient hazard analysis Ongoing Assessments: Audit remediations Relationship management COA
Potential Industry Next Steps (or at least part of a solution) 1. Better leverage resources across industry Audits Supplier information 2. Analytics - anticipating emerging issues FSMA standard is reasonably foreseeable How do we get better analytics? 3. Improve FDA and industry capabilities