C-TPAT
Food Safety
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LMZ has a vital interest and obligation to be at the forefront of food safety issues for the benefit of our clients and ultimately, the consumer. While there have long been measures in place to improve the security of the food supply, in recent years the regulatory environment and related procedures required by destination country authorities have dramatically increased in scope and level of detail. As importers, we are responsible for a key component of the food safety chain that begins in origin countries and ends with delivery of coffee to our clients. LMZ's obligations with respect to food safety involve programs created by U.S. Customs and the Food and Drug Administration, highlighted below:
C-TPAT (Customs-Trade Partnership Against Terrorism)
• LMZ is a C-TPAT certified and validated Tier 2 Importer
• Our C-TPAT Account Number is 14804490
LMZ has been a member of the U.S. Customs and Border Protection's C-TPAT (Customs-Trade Protection Against Terrorism) program since 2005. C-TPAT is a partnership program between the U.S. government and private industry that provides benefits to its membership in return for their commitment to CBP and the U.S. Department of Homeland Security (DHS).
That commitment is demonstrated by members by implementing a minimum set of security criteria throughout one's supply chain for goods bound to the U.S, and improving security on an ongoing basis. This comprehensive program, which had its origins in the aftermath of the 9/11 disaster, has been greatly expanded since its inception and has taken on a scope that applies more broadly to the overall security of the supply chain of goods entering the United States.
Food Safety
The Food Safety Modernization Act (FSMA), passed by Congress late in 2010, was the first major revamp of federal food safety laws since the 1930s, granting new powers to the Food and Drug Administration (FDA) and imposing added responsibilities for food safety throughout the supply chain.
Other provisions include: more frequent FDA inspections of domestic and foreign facilities; required re-registrations by food companies; a presumptive liability that companies which pack, receive or hold foods "knew or should have known" of problem conditions; expanded FDA authority to order administration detention of food where there is "reason to believe" it is "adulterated or misbranded" versus the old threshold of "credible evidence" of a "threat of serious adverse health consequences;" a schedule of new fees for recalls, re-inspections and "fast lane" clearance; a requirement that food producers and manufacturers conduct hazard analyses of reasonably foreseeable hazards, including acts of terrorism, and deploy preventive controls to minimize them; and protection for whistleblowers against retaliation or discrimination.
While effective dates vary widely by provision, some took effect immediately, including the FDA's mandatory recall authority, enhanced access to records and whistleblower protections. The requirement for preventive controls takes effect in mid-2012 and for verification of foreign suppliers in early 2013.
Bi-annual registration requirements begin in 2012, and traceability will not be required for some time. However, the law does take effect whether or not the FDA succeeds in completing the regulations that will further detail the legislative requirements, for which the Agency has two years.
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