FSVP QI Ongoing Verification Maintenance Services
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Supplier-Level and Product-Level Verification Under 21 CFR 1.500–1.514
For entities with an existing FSVP framework, Consultare Inc. Group provides FSVP Maintenance and Ongoing Verification Services designed to support continuous compliance, structured recordkeeping, and inspection readiness in accordance with 21 CFR 1.500–1.514.
FDA FSVP requirements mandate a hierarchical verification approach, consisting of:
- Company-level FSVP program implementation
- Supplier-level verification of foreign suppliers
- Product / material-level verification for each imported SKU
Important: FSVP verification services require at least one (1) foreign supplier and one (1) imported SKU. Supplier-only or product-only verification is not permissible under FDA FSVP regulations.
Scope of Work
1. Supplier-Level FSVP Verification
(Per Supplier – Minimum 1 Supplier Required)
Supplier-level verification activities are conducted in accordance with FDA FSVP requirements and maintained within the Company’s centralized FSVP recordkeeping system (interlinkIQ Supplier Module).
Activities may include:
- Collection and administrative review of supplier identification information
(legal name, address, country of manufacture) - FDA food facility registration confirmation
- Review of supplier preventive controls documentation, where applicable:
- Process controls
- Sanitation controls
- Allergen controls
- Supply-chain controls
- Review of applicable food safety certifications (e.g., GFSI-recognized schemes), where available
- Review of supplier food safety programs and procedures relevant to U.S. food safety compliance
- Review of supplier compliance history, including:
- FDA warning letters
- Import refusals
- Inspection outcomes or enforcement actions
- Review of corrective action documentation related to identified food safety issues
- Reanalysis activities when required under 21 CFR 1.505–1.506
Deliverables (Supplier Level):
- FSVP Supplier Verification Report documenting:
- Supplier information reviewed
- Verification activities performed
- Assessment outcomes and compliance status
- Noted gaps or deficiencies (if any)
- Reanalysis documentation, when applicable
Excludes onsite audits, SOP development, and gap assessments unless separately contracted.
2. Product / Material-Level FSVP Verification
(Per SKU – Minimum 1 SKU Required)
Product-level verification is conducted for each imported SKU or material and is linked to an approved foreign supplier within the FSVP program.
Activities may include:
- Collection and review of product/SKU identification details:
- Product name and description
- Formulation or composition (where applicable)
- Intended use evaluation
- Country of manufacture and linkage to the approved foreign supplier
- Review of product-specific hazard analysis identifying known or reasonably foreseeable hazards
- Review of preventive controls applicable to the product or material:
- Process controls
- Allergen controls
- Sanitation controls
- Supply-chain controls (as applicable)
- Review of Certificates of Analysis (COAs) or analytical documentation supporting verification activities, where applicable
- Review of product-related food safety certifications or attestations, where available
- Review of corrective action documentation related to SKU-specific issues
- Review of change notifications impacting the SKU (e.g., formulation changes, supplier changes, process changes)
Determination of verification activity type and frequency based on risk.
1. Annual Review & Updates of FSVP Documents
- • Comprehensive audit of FSVP records for regulatory accuracy and operational relevance.
- • Updates to reflect new suppliers, products, or FDA regulatory changes.
- • Alignment with 21 CFR 117 (Subpart G), 121, 1.1315, and other applicable rules.
2. Updated Risk Assessment Report
- • Re-evaluation of supplier risks (food safety history, audit results, recalls).
- • Revised risk categorizations with FDA-compliant justifications.
- • Mitigation strategies for high-risk suppliers.
3. Version Control & Documentation Review
- • Tracked revisions with timestamps, change logs, and responsible parties.
- • Centralized, audit-ready records (no missing or outdated files).
- • Compliance with 21 CFR 117.315 (record retention).
Deliverables
– Product information reviewed – Verification activities performed – Assessment outcomes and compliance status – Noted gaps or deficiencies (if any) – Reanalysis documentation, when applicable
• Excludes formulation development, label design, and manufacturing oversight.
Fees and Subscriptions
Supplier-Level Verification (Minimum 1 Supplier + 1 SKU Required)
| Coverage | Fee |
|---|---|
| 1 Supplier + 1 SKU | $75/month (12-month minimum) OR $810/year |
| Each Additional Supplier | $50/month OR $540/year |
Product / SKU-Level Verification (Per SKU)
| Coverage | Fee |
|---|---|
| Per Additional SKU | $25/month (12-month minimum) OR $270/year |
Key Structural Requirement
✔ At least one (1) supplier
✔ At least one (1) SKU
Both are required to initiate and maintain FSVP verification services.