Why Supplier Approval Is the Convergence Point of FSMA and SQF

In today’s global food supply chain, the supplier approval process sits at the intersection of multiple regulatory and certification requirements. Nowhere is this more evident than in the overlap between FSMA’s Foreign Supplier Verification Program (FSVP) and Safe Quality Food (SQF) certification standards.

Enter the Preventive Controls Qualified Individual (PCQI)—tasked not only with hazard analysis and food safety plan development, but also likely tasked with integrating supplier verification systems across both regulatory and audit expectations.

Facilities that align their FSVP and SQF supplier programs under the direction of a knowledgeable PCQI reduce redundancy, increase audit readiness, and strengthen food safety outcomes.

1. FSVP and SQF Share Common Goals, but Different Approaches

Both FSVP and SQF require facilities to assess, approve, and monitor suppliers. However, their frameworks differ:

FSVP (21 CFR Part 1 Subpart L) requires:

• Hazard analysis of imported food and suppliers
• Evaluation of supplier performance and risk
• Verification activities such as sampling, audits, or documentation review
• Corrective actions and reevaluation protocols

SQF (Edition 9) requires:

• Approved supplier programs that include risk-based assessments
• Documented specifications and agreements for all incoming goods
• Verification of supplier performance through audits, COAs, and quality monitoring
• Supplier scorecards or performance metrics

Key Insight: FSVP is focused on regulatory compliance with foreign suppliers, while SQF emphasizes operational consistency and risk control across all suppliers. But both rely on evidence-based decision-making.

2. The PCQI’s Role in Building an Integrated Supplier Program

The PCQI is ideally positioned to unify supplier approval programs into a streamlined system that meets both FSVP and SQF criteria.

They can help:

• Conduct supplier hazard analysis under FSMA and translate those risks into SQF-aligned documentation
• Establish verification activities that fulfill both regulatory and certification requirements (e.g., third-party audits, COA review, sampling)
• Create supplier onboarding SOPs that incorporate FSVP due diligence with SQF documentation needs

Actionable Tip: Map each supplier’s documentation trail to both FSVP and SQF requirements. This helps avoid duplication and provides a clean, auditable record.

3. Navigating FSVP & PCQI Recordkeeping and Traceability Expectations

FSVP and SQF both require detailed documentation—but they don’t always use the same language. The PCQI’s job is to maintain clarity and consistency.

An effective PCQI ensures:

• All FSVP documentation (hazard analysis, evaluations, verifications) is properly filed and updated
• Supplier files also include SQF-required components like product specs, agreements, and audit results
• Traceability protocols satisfy FDA and GFSI trace-back expectations

This dual compliance approach keeps records inspection-ready—regardless of whether it’s the FDA or a GFSI auditor walking through the door.

4. Continuous Supplier Monitoring and Reassessment

Approval isn’t a one-time event. Both FSVP and SQF require ongoing monitoring. The PCQI leads this by:

• Reviewing supplier performance data and identifying trends
• Scheduling reassessments or renewed verification activities based on risk changes
• Coordinating corrective actions when non-conformances are found

Pro Tip: Use supplier scorecards that reflect both FSMA and SQF criteria. This builds a single system that serves dual purposes.

Why Cross-Functional PCQIs Drive Compliance and Confidence

Supplier management is one of the most complex areas of food safety compliance. Facilities that separate FSVP and SQF programs often deal with conflicting processes, audit delays, and unnecessary work.

When a cross-functional PCQI oversees both programs:

• Supplier risk management becomes more proactive
• Documentation systems are cleaner and more consistent
• Audits and inspections are faster, smoother, and more successful

Registrar Corp provides FSVP and PCQI training to help professionals integrate supplier approval systems and prepare for dual compliance demands.