The disclosure statement “not processed to control [identified hazard(s)]” must be made “in documents accompanying the food, in accordance with the practice of the trade.” FDA has advised in draft guidance that appropriate documentation could include labels, labeling, bill of lading, shipment-specific certificates of analysis, and other documents or papers associated with the shipment that a food safety manager for the customer is likely to read.8 FDA also advises that it is not sufficient to reference a website in a document of the trade without including the disclosure statement itself in the document of the trade. FDA also does not recommend that documents such as contractual agreements, letters of guarantee, specifications or terms and conditions be used to communicate the disclosure statement. This is because such documents generally are not specific to a particular shipment, and some of these documents may not be available to the customer’s food safety manager.
