Post-Market Surveillance Procedures

Aligned with FSSC 22000 – ISO-Based Food Safety Management System (FSMS)

Requirement Overview

FSSC 22000 requires organizations to establish processes for monitoring, measuring, analyzing, and evaluating their Food Safety Management System (FSMS). This includes gathering and reviewing information relevant to food safety, customer satisfaction, and system performance to ensure continuous improvement.

Post-market surveillance supports these requirements by systematically monitoring how products perform once they are in the marketplace. It helps organizations:

Monitor product safety and quality after release

Respond to customer complaints and feedback

Detect and manage potential food safety issues in distribution or consumption

Feed real-world data into continuous improvement and risk management processes

This process is particularly valuable for businesses supplying to regulated or export markets.

Key Compliance Objectives

  • Monitor and analyze product performance in the marketplace

    Capture and respond to consumer feedback, complaints, and returns

    Detect emerging issues and non-conformances

    Feed post-market data into CAPA and management review processes

    Maintain traceable and reviewable records

Step-by-Step Compliance Implementation

1. Define Your Post-Market Surveillance Program

  • Include in Scope:

    • Customer complaint handling

      Product performance tracking (e.g., quality, shelf-life)

      Safety alerts or market withdrawals

    Evidence to Maintain:

    • Documented post-market surveillance SOP

      Assigned responsibilities within FSMS

      Product categories and indicators being monitored

2. Monitor and Capture Market Feedback

  • Data Sources:

    • Customer service reports and retailer feedback

      Online reviews, warranty claims, or social media mentions

      Regulatory notifications or public recall databases

    Evidence to Maintain:

    • Complaint and return logs

      Summaries of third-party or consumer feedback

      Internal or external surveillance trend reports

3. Analyze, Investigate, and Escalate

  • Analysis Process:

    • Categorize and risk-assess complaints (e.g., quality vs. safety)

      Conduct investigations for patterns or recurring issues

      Escalate findings to appropriate FSMS and QA functions

    Evidence to Maintain:

    • Root cause analyses (RCA)

      Corrective and preventive action (CAPA) records

      Risk assessments with documented response timelines

4. Implement Corrective and Preventive Actions

  • Possible Actions:

    • Product reformulation or process improvement

      Supplier performance review or corrective actions

      Communication with customers or stakeholders

    Evidence to Maintain:

    • Change logs and updated specifications

      CAPA documentation linked to surveillance findings

      Notifications to stakeholders or authorities if applicable

5. Review and Report Periodically

  • Review Activities:

    • Regular evaluation of surveillance program effectiveness

      Presentation of findings in management review

      Adjustment of monitoring scope based on emerging risks

    Evidence to Maintain:

    • Review meeting minutes

      FSMS performance and surveillance reports

      Preventive action logs

Common Audit Findings & Recommended Fixes

Audit Finding Recommended Action
No defined post-market surveillance process Establish a documented SOP aligned with FSMS monitoring and evaluation requirements
Inadequate complaint handling Implement structured investigation and documentation workflows
Missing trend analysis Create regular reporting mechanisms (monthly or quarterly)
Feedback not integrated into FSMS Ensure surveillance outcomes are reviewed in management review and linked to CAPA

Auditor Verification Checklist (FSSC Context)

Be prepared to demonstrate:

  • Documented complaint handling and surveillance procedures

    Categorized complaint logs and trend reports

    Investigations, RCAs, and CAPAs linked to real issues

    Integration of market data into management review and continuous improvement

    Evidence that findings influence product design, supplier control, or FSMS updates

Implementation Roadmap

Build the Program

  • Define scope and responsibilities

    Develop surveillance SOPs integrated into FSMS

Train and Sample

  • Train staff to collect and log market data

    Establish feedback channels and monitoring tools

Analyze and Improve

  • Perform risk-based evaluations and RCAs

    Initiate CAPA and verify effectiveness

Review and Improve

  • Review program performance regularly

    Feed data into management review and FSMS improvements

Why This Matters?

  • Strengthens consumer protection and regulatory compliance

    Supports continual improvement within the FSMS

    Reduces risk of recalls, repeat complaints, or brand damage

    Demonstrates system maturity and proactive risk management during audits

Support Tools Available

Food Safety Systems provides:

  • Post-market surveillance SOP templates

    Complaint and return logbooks

    CAPA and RCA forms

    Training materials for post-market monitoring and escalation