1. 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

2. 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.

3. Challenges
2. Solutions

4. Challenge 1: Preventing Supplier Recalls

5. Challenge 1: Preventing Supplier Recalls

6. Challenge 1: Preventing Supplier Recalls

7. Challenge 2: FSMA Supplier Verification
Linear

8. Challenge 2: FSMA Supplier Verification
Document Heavy
Linear

9. Challenge 3: Brand Protection

10. 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 . . .

11. 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

12. 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