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#1 Klwarren

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Posted 24 May 2016 - 03:33 PM

Good Afternoon - I hope this communication finds everyone well.  I am looking for some direction / input from the IFSQN community on the topic sharing Supplier information with Customers.

 

We received requests from two (2) of our Customers to supply them with copies of our Raw Material Supplier's audits.  I can not find that this is a regulatory requirement but is a requirement of the Customer's food safety program.  Unless my thought process is way out of line, I am in the mind set that our Third Party Audit Certification should be sufficient in providing the Customer with documentation that they need to ensure that the product(s) supplied by us to them meet all applicable regulations/standards.

 

The Customer has copies of both our Audit Certificate, Audit Report & Findings.  The Audit Report & Findings lists the Supplier Management standards required by the Audit Scheme and shows that no deficiencies were noted.  We have on file with the Customers a LOG and COA for the product(s) supplied to them.

 

I have offered to provide the Customers with a copy of our written Supplier Approval & Control Program, that show that exact standards that our Raw Material Suppliers are required to meet.  I have attempted to explain to the Customers that we may have several Suppliers for one item and that I would need to provide each Supplier's information to them for each product that we provide to them and that is a burdensome task.  However, they are being adament about being provided with a copy of the Raw Material Supplier's Audit.

 

In an effort to resolve the issue, I contacted the Raw Material Suppliers to request consent to release the Audit information to the Customer's - some agreed and some did not.  Two of the Supplier's would not agree due to the fact that the Customer requesting is their competitor.

 

In addition to the above conundrum, the Customers requesting the copies of the Supplier audits also require that the audits are uploaded electronically to their system, there is a fee charged for each upload.  Not that this is a huge deal, however if all customers start requiring this it could get costly.

 

Any insight, input or advice would be greatly appreciated.  

 

Kelly Warren


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#2 jpollock

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Posted 24 May 2016 - 06:51 PM

Thanks for raising this issue. I foresee it happening with us as well. I think it is coming from how some are reading/interpreting the Supply Chain verification segment of FSMA. Can't wait for more experienced hands to chime in.


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#3 Anika

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Posted 24 May 2016 - 07:45 PM

We are BRC certified and auditors in the past had already asked us for traceability back to the manufacturing plant and third party certificates/supplier audits from them as well and this was before BRC issue 7. In one particular example, they wanted audit of a primary packaging company so our CA was to go audit them every year or based on risk.

 

IMO, I foresee the trend to be going towards GFSi recognized scheme and more supplier audits for 'transparency' but I don't know how reliable the certificates themselves are if they are not completely unannounced anyways.

 

For our BRC Issue 7, we made sure to have the manufacturing site name and location of certificate/ supplier audit/supplier questionnaire based on risk assessment and we are a medium sized company and we would need to comply with FSMA by next year anyways.


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#4 Charles.C

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Posted 25 May 2016 - 05:32 AM

Hi Klwarren,

 

However, they are being adament about being provided with a copy of the Raw Material Supplier's Audit.

 

 

If not regulatory, the typical root cause is "Due Diligence" in one of various shapes or forms which is, for some reason, unavoidable by the Customer. Collloquially known as "Covering your Back ".

 

Many, particularly large,  Customers have implemented such a requirement for Decades.

 

Basically it comes down to Leverage and Necessity.

 

Any specific urgency may also relate to your particular Business / Risk.


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Kind Regards,

 

Charles.C


#5 Figaro

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Posted 23 June 2016 - 08:43 AM

Hi All

 

Interesting topic and one that is causing me some concern, namely revealing the names of our suppliers.

 

We are a small importer/exporter of organic dried fruit, we do not repackage our products we merely buy from one source and sell to another.

 

This means that if we reveal the name of our suppliers our customers could go direct to them, cutting us out and saving money.

 

I'm not sure how to solve this, it could be the death knell for us and similar small agent and brokers.

 

Regards

 

Figaro


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#6 BrummyJim

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Posted 23 June 2016 - 12:19 PM

Hi Figaro,

 

Presumably you are BRC Agents & Brokers certified? According to BRC Food Safety, you will have completed due diligence on your suppliers and it will be sufficient. No need to disclose the information. However, the labels on the packaging will give it away.

 

I'm currently in a battle with a broker who refuses to disclose anything (GFSI etc.) until we place an order. I have no way of knowing if the manufacturer will conform to our due diligence requirements without placing the order as the broker has no certification themselves. I'm going somewhere else!


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#7 Figaro

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Posted 23 June 2016 - 12:32 PM

Jim

 

Thanks for the reply.

 

That was my understanding, during discussion with a consultancy however they said we would have to reveal this information. If we did not our customer (if they were BRC accredited) would have a non conformance!

 

There seems to be a great deal of confusion around this subject, it would be good to have a definitive answer.


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#8 Gilles

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Posted 23 June 2016 - 02:02 PM

According to BRC 7 3.5.1.3 if the agent/broker is BRC Agents and Brokers certified you do need to know the manufacturer or packer is. So the auditor of your customer can not give a minor for this.

 

Because of this we are going to add agents and brokers to our BRC audit next year. We do not want to give our suppliers eventhough we also produce and pack alot of our products ourselfs


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#9 Klwarren

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Posted 23 June 2016 - 02:42 PM

As Figaro pointed out, Distributors don't want to provide the Supplier information for fear of companies circumventing the Distributor.  We are a processor and it is a customer requiring that we give them not our our Supplier's information but follow the chain to the farm.  Our Supplier's are refusing to give their Supplier's information for fear of us buying directly - which is an understandable concern.  Even though we have our Supplier's Vendor Packet on file which meets the approval criteria (this Vendor happens to be GFSI Level 2 certified) as are we that isn't enough for our Customer.  So, the solution is... either we give the Customer an audit of a farm that doesn't actually supply the actual products that are produced for them - but keeps them happy or we loose the customer.  This is creating a a check the box mentality and defeats the entire purpose of Food Safety.  I have tried in vain to explain to our Customer to no avail.  The Customer says that it is required as part of FSMA quoting the below - I am at my wits end.  

  • Another entity in the supply chain, such as a broker or distributor, can conduct supplier verification activities, but the receiving facility must review and assess that entity’s documentation of the verification of control of the hazard.

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#10 Charles.C

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Posted 23 June 2016 - 05:21 PM

Hi Klwarren,

 

Actually IIRC, BRC have had to, at least temporarily, retreat somewhat over this issue. Pushback.

 

Are you saying that the situation was different pre-FSMA ?

 

Is the Source document accessible Publicly ?


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Kind Regards,

 

Charles.C


#11 jkoratich712

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Posted 23 June 2016 - 08:52 PM

I just attended a FSPCA (for FSMA) training course and this topic was discussed. If a manufacturer/processer, during their hazard analysis, identifies a hazard with an ingredient that the supplier of the ingredient is controlling, the manufacturer/processer is required to have a supply-chain program. Part of this program is that an onsite audit of the supplier is completed by a qualified auditor. Records for the supply chain program include documentation of this onsite audit including the name of the supplier of the audit, dates of the audit, conclusions of the audit, etc. Basically, if a manufacturer says this ingredient has a hazard and my supplier is controlling it, they manufacturer needs to be sure that their supplier is actually controlling it.

 

The trainer specifically mentioned brokers and the fact that it doesn't matter if you buy from a broker, you still need the information from the supplier.

 

You can read more about it in 21CFR117 Subpart G.


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#12 Charles.C

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Posted 24 June 2016 - 12:23 AM

I just attended a FSPCA (for FSMA) training course and this topic was discussed. If a manufacturer/processer, during their hazard analysis, identifies a hazard with an ingredient that the supplier of the ingredient is controlling, the manufacturer/processer is required to have a supply-chain program. Part of this program is that an onsite audit of the supplier is completed by a qualified auditor. Records for the supply chain program include documentation of this onsite audit including the name of the supplier of the audit, dates of the audit, conclusions of the audit, etc. Basically, if a manufacturer says this ingredient has a hazard and my supplier is controlling it, they manufacturer needs to be sure that their supplier is actually controlling it.

 

The trainer specifically mentioned brokers and the fact that it doesn't matter if you buy from a broker, you still need the information from the supplier.

 

You can read more about it in 21CFR117 Subpart G.

 

Hi jkoratich,

 

Apologies for my ignorance of the USFDA scene.

 

Is the focus on supply chains as mentioned above a new element  due FSMA or simply a continuation of the previous control system ?

(for some reason none of the headings in subpart G [or the rest of  the page] seem to be expandable at this time for me)


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Kind Regards,

 

Charles.C


#13 Figaro

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Posted 24 June 2016 - 08:20 AM

Charles

 

You commented that BRC have had to retreat over the supplier disclosure issue, can you provide any more information about the form that this retreat has taken.

 

Thanks

 

Figaro.


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#14 Charles.C

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Posted 24 June 2016 - 09:33 AM

Charles

 

You commented that BRC have had to retreat over the supplier disclosure issue, can you provide any more information about the form that this retreat has taken.

 

Thanks

 

Figaro.

 

Hi Figaro,

 

See the discussions in BRC threads (1,2) below and attachment F081 in posts 21/ thread (1) or 10/thread (2).

 

(1)
http://www.ifsqn.com...-approval-3513/

 

(2)
http://www.ifsqn.com...nts-or-brokers/


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Kind Regards,

 

Charles.C


#15 Figaro

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Posted 24 June 2016 - 10:45 AM

Charles

 

I had seen that information about the deferment but couldn't recall where, very helpful thanks.

 

Do you (or anyone) know if the deferment is or will be extended?

 

The phrasing in 3.5.1.3 seems to be saying that if the agent or broker is BRC certified they don't have to name their supplier or am I being overly optimistic!

 

Figaro


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#16 jkoratich712

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Posted 24 June 2016 - 08:08 PM

Hi jkoratich,

 

Apologies for my ignorance of the USFDA scene.

 

Is the focus on supply chains as mentioned above a new element  due FSMA or simply a continuation of the previous control system ?

(for some reason none of the headings in subpart G [or the rest of  the page] seem to be expandable at this time for me)

 

I believe it is new. Under the new Preventive Controls for Human Food, it is required to have a Supply Chain Program if your supplier is controlling a hazard.


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#17 Charles.C

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Posted 25 June 2016 - 03:10 AM

Charles

 

I had seen that information about the deferment but couldn't recall where, very helpful thanks.

 

Do you (or anyone) know if the deferment is or will be extended?

 

The phrasing in 3.5.1.3 seems to be saying that if the agent or broker is BRC certified they don't have to name their supplier or am I being overly optimistic!

 

Figaro

 

Hi Figaro,

 

The attachment f081 now only seems to be locatable by searching on the website so deferment status unknown.

 

Cannot see any mention of extension on website (painful to navigate). People who get the most recent Newsletters or can access "Participate" may know.

 

Answer to "phrasing" may be in BRC's IG. Optimism is injudicial  where BRC is concerned.


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Kind Regards,

 

Charles.C


#18 Figaro

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Posted 27 June 2016 - 01:38 PM

Charles

 

Thank you for your reply, I have noted you advice re optimism and BRC!!


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#19 ShannieB89

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Posted 27 June 2016 - 04:03 PM

  • Another entity in the supply chain, such as a broker or distributor, can conduct supplier verification activities, but the receiving facility must review and assess that entity’s documentation of the verification of control of the hazard.

 

Do you think that brokers and distributors are willing to take such an action? It will be costly for them and not only that, they might not be able to visit international suppliers which is also an issue with the receiving facility experiences. This might be side-tracked from the original query but due to this being an issue with brokers/distributors in getting food safety related documentations. receiving facilities should probably stipulate that before entering a contract with brokers/distributors, that they can guarantee the availability of food safety documents from manufacturers. Probably easier said than done. 


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