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Issue of the Month

The #1 FSMA Element Most Produce Importers Fail to Get Right

By Dan Simonsen, EAS Consulting Group Independent Consultant

Many produce importers focus on supplier documentation and audit records but overlook one of the most frequently cited FSVP requirements: demonstrating that foreign suppliers provide the same level of public health protection required by FDA's Produce Safety Rule.

Dan Simonsen explains why supplier evaluations under 21 CFR §§ 1.502 and 1.505 continue to generate FDA observations and how relying solely on questionnaires or outdated audit certificates often falls short of regulatory expectations.

The article outlines a practical approach for documenting supplier evaluations using FDA-recognized audit standards to support compliance with the Produce Safety Rule.

Whether you are reviewing an existing Foreign Supplier Verification Program (FSVP) or evaluating a new produce supplier, understanding these expectations can help strengthen your compliance program before an FDA inspection.

Under the Microscope

Pesticide Residue Testing: MRLs, Methods, Labs, & Regulations Explained

Reviewed and Approved by Steven Rogers, Chemistry Manager, Certified Laboratories 

As a member of the Certified Group and Food Safety Net Services, EAS clients have access to world-renowned testing laboratories that meet your organization’s sophisticated needs. In this column, you’ll hear about their capabilities, environmental challenges and more. We hope you’ll enjoy a look “under the microscope.”

As a member of the Certified Group and Food Safety Net Services, EAS clients have access to world-renowned testing laboratory expertise. In this column, you'll hear about their capabilities, environmental challenges, and more. We hope you'll enjoy a look "under the microscope."

Pesticide residue testing plays an important role in food safety, regulatory compliance, and consumer confidence. Understanding Maximum Residue Limits (MRLs), selecting the right analytical methods, and working with a qualified laboratory are all critical to verifying that products meet regulatory requirements and market expectations. 

This article explains how laboratories use advanced analytical techniques such as LC-MS/MS and GC-MS/MS to detect pesticide residues, why MRLs vary by market, and what food manufacturers, importers, and retailers should consider when selecting a testing partner.

Whether you're developing a testing program, evaluating suppliers, or preparing products for domestic or international markets, understanding pesticide residue testing can help strengthen your food safety program and support regulatory compliance.

FDA and USDA Regulatory Updates

Key regulatory developments shaping compliance and market access:

▪ California Food Date Labeling Requirements Take Effect July 1

▪ CFIA Food Fraud Report Highlights Ongoing Food Authenticity Challenges

▪ FDA Announces Public Meeting on Listeria monocytogenes Prevention

▪ FDA Calls on Infant Formula Industry to Strengthen Supplier Oversight

▪ FDA Rolls Out New Features in CTP Portal NextGen to Enhance Application Submission Process

▪ FDA Announces FY2027 FSMA User Fees for VQIP and TPP

Stay current with EAS events, training, and industry engagement:

Consultant Corner

EAS offers over 200 independent consultants strategically located around the globe whose expertise provide core value for clients.

Meet This Month's Author

Dan Simonsen

EAS Consulting Group, Independent Consultant

Dan Simonsen spent over 15 years at the U.S. Food and Drug Administration, beginning as a Consumer Safety Officer conducting inspections of food, beverage, dietary supplement, cosmetic and imported consumer products across the Los Angeles district, with a particular focus on Foreign Supplier Verification Program (FSVP) reviews at the LA/Long Beach port complex. He went on to serve as a Compliance Officer in FDA's Office of Import Operations, where he directed enforcement actions — including Warning Letters, Import Alerts, and Form 483 responses — and served as the agency's district-level authority on import admissibility, labeling, and food safety law. In that role, he worked closely with FDA's Office of Chief Counsel to build legally defensible enforcement action and trained both internal investigators and industry stakeholders on FSMA-related compliance topics.

In 2026, Dan began working with EAS Consulting as an Independent Consultant, helping importers and regulated companies navigate FDA detention hold & Import Alert removal, FSVP program design, and Form 483 or Warning Letter remediation. Drawing on his firsthand experience on the enforcement side, Dan now helps clients understand what FDA expects and how to build compliance programs that hold up to scrutiny.