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Certificate of Analysis - Co-packer of finished product


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#1 QATim

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Posted 24 January 2012 - 07:20 PM

I have a company that takes our product in bulk and packs it into different sized packaging. They are telling me that SQF requires them to receive a COA from us for every lot of bulk lots we send them. I am confused because we are sending them the finished product not a raw material, they pack it and send it right back to us. It does not go to anyone else and it is inspected upon arrival back here prior to being shipped to customers. Am I wrong thinking that they do not need a COA from us? Please help! I could not find anything specific in the code to support what I think I know :)



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#2 esquef

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Posted 24 January 2012 - 07:39 PM

Hi Tim,

I work for a company and some of the work we do is repacking (or co-packing). You are a supplier to that company you refer to (as well as a customer). As a supplier the co-packer has to deal with your company as such and they have an Approved Supplier program as required by SQF. There are any number of ways to build an Approved Supplier program, and many companies require COA's to accompany all incoming materials as a part of it. You may not consider it a "raw material", but your co-packer may have to. It's likely that they consider it a raw material until it's repacked, and at that point it's a finished product. In other words, since the co-packer is a part of the supply chain and there's a possibility that something that affects product safety or quality in the repacking operation, they likely have to deal with the incoming "finished product" (from your point of view) as a raw material.

This kind of business model is a nightmare from a GFSI point of view; who's the customer? Who's the supplier? A lot of semantics involved, that's for sure.

Regards,
esquef


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#3 TonyMc

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Posted 26 January 2012 - 03:33 PM

All the company needs is an Approved Supplier Program. They can define that in any way they wish. The approved supplier of the product can be listed as the sole supplier and it is up to them to decide if a COA is required. In this case I would say it is not required and if they are concerned then they could simply do a risk analysis.


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#4 QATim

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Posted 26 January 2012 - 07:58 PM

Thank you both for your input it is very helpful.


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#5 GMO

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Posted 27 January 2012 - 06:59 AM

Could you argue that a certificate of conformance is sufficient? Then you could state on each delivery note "this product has been packed using a HACCP based food safety system and has been found to conform with all CCP monitoring activities" or something similar?


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#6 esquef

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Posted 27 January 2012 - 05:24 PM

All the company needs is an Approved Supplier Program. They can define that in any way they wish. The approved supplier of the product can be listed as the sole supplier and it is up to them to decide if a COA is required. In this case I would say it is not required and if they are concerned then they could simply do a risk analysis.



This is true, however if the co-packer is SQF certified and they state in their approved supplier program that a COA is required for all incoming materials they'd have to change their SQF Approved Supplier policy (Pre-requisite program 6.10) which can be time consuming to document the change properly for their re-certification audit. IMO it'd be easier to just supply the COA.
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#7 GMO

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Posted 27 January 2012 - 10:03 PM

This is true, however if the co-packer is SQF certified and they state in their approved supplier program that a COA is required for all incoming materials they'd have to change their SQF Approved Supplier policy (Pre-requisite program 6.10) which can be time consuming to document the change properly for their re-certification audit. IMO it'd be easier to just supply the COA.


But a COA suggests you test every batch. That could be very expensive.
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#8 esquef

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Posted 27 January 2012 - 10:13 PM

But a COA suggests you test every batch. That could be very expensive.



SQF is very flexible. As long as you meet the code you simply say what you do and do what you say. You'd only have to verify COA's if you say that's what you do.
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#9 GMO

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Posted 28 January 2012 - 07:04 AM

SQF is very flexible. As long as you meet the code you simply say what you do and do what you say. You'd only have to verify COA's if you say that's what you do.



I'm a bit confused. If I received a "Certificate of Analysis", I would expect the supplying company to have done some form of analysis on that batch. If I received a "Certificate of Conformance", I would expect the parameters listed to be assured by their FSQMS / HACCP plan with verification testing but not testing per batch. Do you not agree to issue a COA without doing any analysis is a little disingenuous? Although SQF seems to have different meaning to words than the rest of the world (Validation for example), a COA is a document which leaves your company and so needs to be meaningful to companies who work to other standards.

Edited by GMO, 28 January 2012 - 07:04 AM.

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#10 GOC

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Posted 28 January 2012 - 06:30 PM

I have a company that takes our product in bulk and packs it into different sized packaging. They are telling me that SQF requires them to receive a COA from us for every lot of bulk lots we send them. I am confused because we are sending them the finished product not a raw material, they pack it and send it right back to us. It does not go to anyone else and it is inspected upon arrival back here prior to being shipped to customers. Am I wrong thinking that they do not need a COA from us? Please help! I could not find anything specific in the code to support what I think I know :)





This might get classified as a sticky-wicket item, however, they will need to explain on their end (to an Auditor for instance) why there is no COA. Thus, an explanation would be needed - in writing is best. If you have a COA for their files send them one along with a note as to why you are not going to issue one with every ship out. That should satisfy.
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Glenn

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