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“Exactly What We Needed” – Azzule’s Core Support to the Rescue

PrimusLabs and Azzule work with entities throughout the fresh produce industry and all facets of the supply chain, including companies big, small, and somewhere in between. This is the true story of a very small company that has just signed a contract for Azzule’s Core Support Services. The names of the company, its location, suppliers, and owners have been changed.

Adelphia Growers Inc. is a very small company, comprised only of the husband and wife team of Sam and Kristie Palance. Adelphia conducts business in Maricopa County, Arizona, just outside of Phoenix. Sam and Kristie’s middle-of-the-supply-chain business focuses on only one commodity – cucumbers, and they have a small number of domestic cucumber suppliers, as well as one foreign supplier, located in Mexico. Adelphia sells those cucumbers to a handful of small retail buyers.

Adelphia began working with Azzule several years ago when it set up a free SCP account. Though Sam and Kristie were not trained in food safety, they had grown up in agriculture. They learned what they could, though even they would admit, there were gaps in their knowledge base.

For instance, they didn’t know about HACCP plans, but that was understandable considering that Sam and Kristie didn’t directly handle any of the produce that they bought and sold. After all, they ran their company out of their home. Still, for most of the 13 years they’d been in business, they had taken the issue of food safety very seriously, eventually using the SCP to transfer food safety documents to their customers to comply with those customers’ requirements.

Sam and Kristie were aware of the fact that they were the legal importer-of-record for Adelphia’s single foreign supplier – Rancho Tierra Marrón Santa Barbara, near San Quintin in Baja California. In this regard, Sam and Kristie differ from many other small importers in the US. Many small importers, especially those that are not located near border communities or major ports, are not even aware of the fact that they are the de facto importers-of-records for their foreign suppliers.

FSVP regulates “the US owner or cosignee for an article of food that is being offered for import into the United States. If there is no US owner or cosignee for an article of food at the time of US entry, the importer is the US agent or representative of the foreign owner or cosignee at the time of entry, as confirmed in a signed statement of consent to serve as the importer for the purposes of the FSVP regulation” (21CFR 1.500).

Though Adelphia had signed a statement of consent with Rancho Tierra Marrón Santa Monica, Sam and Kristie did not know very much about the Foreign Supplier Verification Program (FSVP) of the Food Safety Modernization Act (FSMA), and wearing as many hats as they already did in their small business, they were largely in the dark about importer requirements under the FSVP rule. In fact, they didn’t think that FSVP applied to them. They’d checked the FDA’s list of importers-of-record, and Adelphia wasn’t listed.

That all changed a month ago when the FDA sent Adelphia a letter informing Sam and Kristie that they were going to be inspected as importers under the FSVP rule. Because of Covid-19 restrictions, the FDA conducted the inspection remotely, and Adelphia was asked to produce documents. The FDA asked for Rancho Tierra Marrón’s docs and wanted to know who was serving as Adelphia’s Qualified Individual. Neither Sam nor Kristie knew what to do or say. Because their contact at Ranch Tierra Marrón did not speak English and they did not speak Spanish, Sam and Kristie did not have the HACCP plan, audit results, lab tests, and other documents from Rancho Tierra Marrón that the FDA was requesting, nor did they know what a Qualified Individual was supposed to do.

The FDA informed Sam and Kristie that they had two weeks to produce all of the appropriate documents. Again, they were lost and a little afraid. They wondered if their business could survive, but they got to work. Sam looked up companies online that provided assistance with FSVP and discovered that Azzule’s website talked about its Core Support Services. Kristie sent an email to request a starter packet. The Azzule salesperson Brittney Potter called Kristie back and set up a meeting with Sam and her to explain more about Core Support. Brittney asked Cynthia Temblador, Eric Peterson, and McKenzie Barber from Azzule to participate in a demonstration of Core.

Sam and Kristie were grateful for the detailed explanation, but it was the simplicity of the program that really attracted them. They liked the way it worked. One of Azzule’s bilingual experts would serve as their Qualified Individual or QI (someone that the FDA recognizes for their food safety knowledge), and though Azzule would contact Rancho Tierra Marrón on their behalf, they would retain the right to make the final decision on whether to accept cucumbers from the farm.

And the price was right, too.

Having only one foreign supplier, they were thankful that they wouldn’t have to spend an arm and a leg on a program designed for a company with thousands of foreign suppliers. Adelphia quickly signed a two-year contract, and Azzule got to work to gather up everything they needed. Azzule would store all of the documents in Adelphia’s SCP account.

In the end, a potentially catastrophic disaster had been averted. Kristie put it best, “You guys showed up at the right time. What you’re doing for us is exactly what we needed.”