1 reply to this topic

[gkcaduceus]

We are IQF vegetable manufacturer, and we contract grow all of our raw material product. This is captured in our risk assessment, and we would consider our suppliers (many of have been with us for years) low risk.   We already perform a documented site audit (based on our criteria) for all of our growers, and we are in the fields on a routine basis.  It seems to be vague in it application to agricultural processing operations.  Most of the requirements seem applicable to previously processed ingredients.Would this type of purchasing fall under 3.5.1.4 as bulk commodity purchase?  Do we need to take any additional steps to comply with the requirements in the section? 

 

In addition, we do not use primary packaging (packaging seen by the consumer).  Our food cantact packaging (ex.poly liners cor cases and totes) is included, and we have performed the risk assessment.  We deem them low risk due to historical performance, and we require both a 3rd party audit and our internal questionnaire.  Do we need to perform a risk assessment for our carboard/fiber secondary packaging?

[trubertq]

I don't think so.

 

I work with Fish processors and they have the same issue in that they buy directly from fishermen. I'm approaching it from the angle that I have historical evidence. They are High risk suppliers in my clients case but all the product is ( supposed to be ) live when it comes on site so substitution and adulteration are not an issue. It won't be feasible to do a site audit on all the boats so we shall have to use historical evidence to risk assess and approve.

 

Non-contact packaging is low risk IMO and you have risk assessed and site audited I think you are well covered.