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Sec. 3.5.1.3 Raw materials from Agents or Brokers


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#1 rewel

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Posted 05 November 2015 - 11:11 PM

Hi all,

 

We purchase additives i.e Copper sulphate and Potassium metasulphites from a supplier. Are suppliers the same as agents/broker? do i still need to know the identity of the last manufacturer/packer? all suppliers are approved.

 

Any help would be appreciated.

 

Cheers,

Rob


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#2 Tony-C

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Posted 06 November 2015 - 04:04 AM

Hi Rob,

 

Agents/Brokers can be suppliers but need to be managed to ensure supplier assurance and traceability from the BRC Interpretation Guideline:

 

'The purpose of this clause is to ensure that, where a site has purchased a raw material from an agent or broker, the site has sufficient information to ensure traceability and to enable the approval of the last processor of the raw material, the last point of packing or the consolidation place for bulk commodity products, as described in clause 3.5.1.2. This information can be provided directly by the manufacturer, processor, packer or consolidator or alternatively through the agent or broker.

Where the agent or broker is itself certificated to the BRC Global Standard for Agents and Brokers or to the wholesale module of the BRC Global Standard for Storage and Distribution, the requirement to approve the processor, packer or consolidator is not applicable, as the requirements of these Standards ensure that effective systems for supplier approval and traceability are in place. However, the site will still be expected to know the identity of the processor, packer or consolidator.'

 

 

 

Regards,

 

Tony

 

 


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#3 rewel

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Posted 11 November 2015 - 12:54 AM

Thank you for your reply Tony,

 

I'm still a little confused. All raw materials have batch numbers and the manufacturer stated on them all suppliers are approved through the our approved supplier program. i just don't know how many steps it has taken to get to us. some suppliers can't give us that info and some don't want to tell us where they get it from in fear that we are just going to go to that supplier.

 

do you think having batch numbers and having them as an approved supplier is sufficient. i have conducted a vulnerability test on all raw materials and everything is low risk.

 

Cheers,

Rob


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#4 Tony-C

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Posted 11 November 2015 - 04:08 AM

Thank you for your reply Tony,

 

I'm still a little confused. All raw materials have batch numbers and the manufacturer stated on them all suppliers are approved through the our approved supplier program. i just don't know how many steps it has taken to get to us. some suppliers can't give us that info and some don't want to tell us where they get it from in fear that we are just going to go to that supplier.

 

do you think having batch numbers and having them as an approved supplier is sufficient. i have conducted a vulnerability test on all raw materials and everything is low risk.

 

Cheers,

Rob

 

Hi Rob,

 

I think the standard is quite clear:

 

3.5.1.3 Where raw materials are purchased from agents or brokers, the site shall know the identity of the last manufacturer or packer, or for bulk commodity products the consolidation place of the raw material.
Information to enable the approval of the manufacturer, packer or consolidator, as in clause 3.5.1.2, shall be obtained from the agent/broker or directly from the supplier, unless the agent/broker is themselves certificated to the BRC Global Standard for Agents and Brokers.

 

I think you need to point this out to your suppliers. If you are wanting BRC certification then you may have to consider finding new suppliers if they don't want to comply with your requests.

 

Regards,

 

Tony


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#5 pandu

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Posted 12 November 2015 - 08:55 AM

Hi Tony,

 

As Rob mentioned before agents/brokers are sometimes reluctant to provide information about suppliers and thus, clause 3.5.1.3 will be tricky to meet until agents/brokers are BRC-certified.

 

I've heard that BRC have decided to defer this clause for 1 year (until July 2016). In other words agents/brokers are being encoureged to get a BRC (why not a GFSI-recognised???) certificate.

 

Hope it helps.

 

Best regards,

 

Pedro


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#6 Anika

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Posted 10 February 2016 - 02:24 PM

I think the idea is Site knows where exactly their raw materials are coming from. I agree with Tony. Even if suppliers/vendors refuse to give that information, BRC put that clause in so that they are forced to comply. Not giving out that information is a business decision but the site has to make a food safety decision on whether and how they can accept raw materials .

 

Pedro why BRC for agents and brokers are being suggested, I don't know. Could be BRC wants to make more money but I'm akso not sure whether other GFSi has programs for 'agents and brokers' as well.


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#7 Anika

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Posted 10 February 2016 - 02:39 PM

I have a different question related to Agents and Brokers. :bug:

 

If suppliers are GFSI certified, but vendors(agents and brokers) are not a manufacturing company with no GFSI, would they need to have 'BRC Agents and brokers'.

Note: no repacking is done at vendors site

 

Has there been a gap analysis published for BRC for  agents and brokers?

 

So far, we have them as low risk and have Vendor Security questionnaires for most

 

Thank you in advance!


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#8 BrummyJim

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Posted 10 February 2016 - 04:28 PM

From a BRC perspective, I believe that you would need to approve the manufacturers as well as the vendors. If the vendors don't like this, you should explain that in order to retain you BRC this is the only option. Of course, the vendors might chose to adopt IFS Broker or BRC Agents & Brokers!

 

As for a gap analysis, it's available on the BRC website. Look under the Agents & Brokers information and FAQ.


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#9 Charles.C

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Posted 10 February 2016 - 04:35 PM

I have a different question related to Agents and Brokers. :bug:

 

If suppliers are GFSI certified, but vendors(agents and brokers) are not a manufacturing company with no GFSI, would they need to have 'BRC Agents and brokers'.

Note: no repacking is done at vendors site

 

Has there been a gap analysis published for BRC for  agents and brokers?

 

So far, we have them as low risk and have Vendor Security questionnaires for most

 

Thank you in advance!

 

Hi Anika,

 

GFSI is relatively Generic.

 

GFSI (6.4-2015) makes no reference regarding the activities/Scope of Brokers/Agents other than

 

Food Broker / Agent - The supply of finished food and feed product

 

GFSI (glossary) defines a Supplier as -

 

An organisation supplying food, feed or a service.

 

Some (random) examples of GFSI Requirements –

 

Supplier performance

The standard shall require that the organisation establish, implement and maintain procedures for the evaluation, approval and continued monitoring of suppliers, which have an effect on food safety. The results of evaluations, investigations and follow up actions shall be recorded.

 

Supply management

The standard shall require that the organisation controls  the supply management processes to ensure that all externally sourced materials and services, which have an effect on food safe packaging materials, conform to specifier and regulatory requirements.

 

Traceability

The standard shall require that the organisation establish, implement and maintain appropriate procedures and systems to ensure:

Identification of any outsourced production, inputs or services related to food safety,

A complete record of in-process material or final product and packaging throughout the production process,

A record of purchaser and delivery destination for all animal, fish or seafood products,

Product identification that includes, as a minimum, the origin (producer and country) and the date of production or packing.

 

Perhaps GFSI-2016 will have more to say about Brokers/Agents.

 

PS - It is impossible for suppliers to be "GFSI certified". GFSI certify no-one despite the frequent claims to fame.

PPS - Note that this topic partially overlaps a parallel thread -

http://www.ifsqn.com...-approval-3513/


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Kind Regards,

 

Charles.C


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#10 Tony-C

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Posted 11 February 2016 - 05:02 AM

Hi All,

 

Further to the information provided in my previous post and the questions asked subsequently:

 

BRC Global Standard for Food Safety Issue 7 Position Statement F081 - Phased introduction of clause 3.5.1.3:

Attached File  F081 - Phased introduction of Clause 3.5.1.3.pdf   92.68KB   39 downloads

BRC Agents and Brokers Self-assessment tool

Regarding the GFSI Guidance Document and Certification Schemes:
Further scope extensions are underway for Food Brokers/Agents, Retail/Wholesale, Catering, Equipment Manufacturing and Food Safety Services.
 

Kind regards,

 

Tony


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#11 JanisM

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Posted 27 June 2016 - 08:56 AM

If we have goods from IFS certified broker, we still need to ask him to send us all information directly from manufacturer (i.e. questionnaire) ? Because clause 3.5.1.3 says nothing about GFSI-recognized agents, but strictly only BRC agents.

 

Which means if only agent/broker is BRC certified, we can accept Questionnaire filled by him and otherwise we do need info directly from manufacturer?


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