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Grain Elevator as a Supplier?

Supplier FSMA grain GFSI

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#1 JenBurnside

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Posted 23 March 2016 - 03:49 PM

We process whole grain in a conditioning plant. The plant is entirely fed by a grain elevator that sits adjacent to it with a line that directly feeds the Conditioning Plant. 
Though they are attached by the ingredient line, they are separate facilities. (under the same company name)

We are working toward GFSI certification and we only include the Conditioning Plant in our scope because the elevator is simply a separate holding and transfer operation. 
During a customer pre-audit meeting this morning, the auditor asked about supplier controls and if we work closely with the elevator to ensure they are providing safe ingredients.

Does this mean that our elevator is technically considered a supplier?

This is something that never occurred to me before as we all (conditioning and elevator office staff) work in the same small office and even though the operations are separate, we've always looked at the two as one company and never considered that under FSMA or our customer requirements, we might need to treat the elevator as a supplier.

If this is the case, do we need to have a supplier control program in place for the elevator? 

I am appreciative of any thoughts or suggestions anyone has on this. 

 


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#2 QAGB

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Posted 23 March 2016 - 06:19 PM

Hi JenBurnside,

 

I'd have to lean towards it being a supplier unless you guys have any cross-over functions and/or shared procedures. If both sides do in fact operate totally separate from one another, it's almost certain to be a supplier. 

 

When/if you have customer audits, are both sides audited at the same time? Do you perform internal audits on the grain elevator, and is it included in your GMP inspections? I'm just trying to get a little more information here.

 

QAGB


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#3 JenBurnside

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Posted 23 March 2016 - 07:30 PM

Hi JenBurnside,

 

I'd have to lean towards it being a supplier unless you guys have any cross-over functions and/or shared procedures. If both sides do in fact operate totally separate from one another, it's almost certain to be a supplier. 

 

When/if you have customer audits, are both sides audited at the same time? Do you perform internal audits on the grain elevator, and is it included in your GMP inspections? I'm just trying to get a little more information here.

 

QAGB

 

When we have customer audits, we may take the auditor through the elevator to explain our storage and transfer processes but that part of the facility is not included in the audit. We've had AIB inspections and the Conditioning Plant and Elevator are done the same day but they are are treated as separate audits. GMP inspections are also separated. 
I don't know why we never considered this before. Until we had to worry about supplier controls, it just never came up.

 


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#4 QAGB

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Posted 23 March 2016 - 07:38 PM

When we have customer audits, we may take the auditor through the elevator to explain our storage and transfer processes but that part of the facility is not included in the audit. We've had AIB inspections and the Conditioning Plant and Elevator are done the same day but they are are treated as separate audits. GMP inspections are also separated. 
I don't know why we never considered this before. Until we had to worry about supplier controls, it just never came up.

 

 

 

I would definitely consider them to be a supplier in your case.

 

Your situation is somewhat similar to ours. We have three divisions to our company, one division is attached to this one, and the other division is about 15 miles away. The one attached has its own everything and is totally separate. We supply to them, but they don't supply to us. The other (third) division 15 miles away supplies this division mostly. We treat them as a supplier; we get documentation from them, and every process is separate. We do work together on some things (for example: if they need one of us to conduct an internal audit we'll help), but they are in fact separate. We didn't consider that when we started really digging into our supplier approval program, because we thought since we were basically the same company, we wouldn't need to do so. However, it did make sense once we broke it down and realized we didn't know as much as we thought about the other side.

 

QAGB


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