31 replies to this topic

[QM-OS]

IMO, "Supplier Risk" should be included if you are risk assessing a material from the supplier.

If you have a high risk supplier, (why are you buying from them in the first place  ), that should certainly play a part in the risk assessment of the material.

 

Marshall

 

It could be because of severeal reasons.

Not being able to get the product from other supplier, it's a "niche" product, certain origin, etc.

[QAGB]

It could be because of severeal reasons.

Not being able to get the product from other supplier, it's a "niche" product, certain origin, etc.

 Yep - we had this problem. We had several niche products which weren't widely available from multiple suppliers. We also found with a couple products, the taste profile widely varied by supplier, so we couldn't just switch to another very easily. 

[dido_]

Hi QM-OS,

Thanks for your reply.

Which criterias did you used to combine the result of the raw material assessment? Clearly, defining food-contact material supplier as "not low risk supplier" will not be applicable for us, since our products are spices. Maybe your method could show me a way.

 

Didem

 

 

 

In the first 5 or so years of our BRC work we didn't have the product risk assessment in consideration when evaluating suppliers.

None of the auditors during these years found this to be a non-compliance. 

 

 

Awhile ago we changed our routine for evaluating suppliers. We now take the product risk and combine it with overall supplier risk and that generates a final risk "grade".

If a supplier deliver different products with different risk levels we consider the higher risk when generating the final grade.

So far, none of the auditors have had any problems with this way, either...

[Charles.C]

Hi QM-OS,

Thanks for your reply.

Which criterias did you used to combine the result of the raw material assessment? Clearly, defining food-contact material supplier as "not low risk supplier" will not be applicable for us, since our products are spices. Maybe your method could show me a way.

 

Didem

 

Hi Didem,

 

I'm also interested in the answer to yr query.

 

The BRC8 Food  Interpretation Guidelines mentions approx. 10 factors for raw materials risk assessment (excluding food fraud) which "should"(could?) be included in the analysis. Possibly a little overboard but certainly offers scope for manipulation/prioritisation if so desired.

 

Combining risks is a much discussed/contentious topic in the business arena and the initial logics (but not the later) in my own approach were vaguely developed from the opinions in this document  -

 

 Risk Aggregation.pdf   856.12KB   51 downloads

 

(It's also worth noting the caveats at end of the article).

 

I'm guessing that these kind of complications  have been one reason for the, so far, 6-year delay in FSMA's promised list of "high risk" food products.

 

PS - (paraphrasing Marshall) the evaluation of a Supplier's intrinsic Capability is surely also related to "Supplier Approval" ? (Certainly has been in my audit experiences).

 

PPS - JFI here is the FDA's draft proposal as to their (then) thinking of the basis for designation of a Food as "High Risk". Somewhat more "defined" than the BRC viewpoint.

 

 FDA draft high risk foods,2014.pdf   217.01KB   27 downloads

[Charles.C]

As one more contribution, I just noticed this, IMO, quite informative/concise BRC  "Procedure"  for the titled Objective   -

 

 Supplier Risk Assessment.pdf   38.16KB   59 downloads

 

And, just to crystallize the thought process that is going on, another quote  -

The purpose of a raw material risk assessment is to assess the inherent risks of the raw materials. This can happen even before the supplier has been decided.

 

The purpose of a supplier approval & monitoring risk assessment is to take the output from the raw material risk assessment and combine this with the risk of getting that raw material from a particular supplier.

 

For example, the raw material risk assessment may determine that raw filleted fish is a high risk ingredient, because of the micro risks from fish and also the possibility of left over bones from the filleting process.  The high risk result would then be put into the supplier approval & monitoring risk assessment for each supplier who supplies the fish.  One supplier may be really great and therefore they would come out with a lower risk result and another supplier may not be so great and come out with a higher risk result.

 

The purpose of a raw material risk assessment is to assess the inherent risks associated with purchasing the raw materials, so that controls can be put in place to ensure that this doesn’t impact on production and more importantly on the consumer.

 

An inherent risk is something that is characteristic of that raw material, a bit like it’s expected that you’ll get a small amount of stones in raw cereals or dried fruit, or salmonella in raw egg.  A supplier risk assessment doesn’t assess the inherent risk of the raw materials.

https://techni-k.co....sletter_20_RMRA

(PS - I don't entirely agree with the final sentence in quote above since the specific requirements, eg GMP, for a supplier of  raw material may relate to it's subsequent intended usage)

Edited by Charles.C, 17 December 2019 - 05:56 AM.
added

[dido_]

Charles,

 

Thank you very much for your effort and help.

 

I totaly agree with you that spices -as raw materials- should not be considered as low risk. But in practical it is really very difficult to manage and document. I have just finished my risk analysis. I guess the best will be taking the comments of our auditor. We'll wait and see:)

Merry Christmas btw,

 

Dido,

 

As one more contribution, I just noticed this, IMO, quite informative/concise BRC  "Procedure"  for the titled Objective   -

 

Supplier Risk Assessment.pdf

 

And, just to crystallize the thought process that is going on, another quote  -

(PS - I don't entirely agree with the final sentence in quote above since the specific requirements, eg GMP, for a supplier of  raw material may relate to it's subsequent intended usage)

[QM-OS]

We go by the BRC Food clause 3.5.1.1 (and guidelines) when doing the product risk assessment.

We also look historically, and take into account what type of production we have (with the BRC Food standard, appendix 2).