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Will a certificate of conformance satisfy clause 2.3.2?


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#1 hbrannan

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Posted 13 July 2016 - 03:30 PM

Good morning! (at least it's morning in my corner of the globe)

 

I've been scanning topics for a while, and this forum has been a wonderful tool for answering my ongoing questions regarding our SQF certification. However, I felt the need for my first post, as I've not seen the answer I'm seeking for this topic.

 

I am newly entered into the product quality world, and am in a situation with my company where our customers are asking for GFSI certification in order to continue doing business with them at the level at which management wishes to be.  Additionally, there are new customers we'd like to partner with that require this as well, so SQF, here we come!  Oh and management is completely on board with the idea and I have tons of support which is nice, but this also brings a tight deadline with it.

 

A little background, we are a plastic-injection molding manufacturer of drinking cups.  Our incoming raw materials consist of polypropylene resin and colorants, manufactured PET (polyethylene terephthalate) drinking cups, and corrugate packaging for shipping of the finished product.  I suppose we could also consider our ink supplier as well (we mold the cups as well as print custom artwork). 

 

My trouble is in constructing a raw materials and supplier approval process.  I am getting ready to send notification to each of our raw materials suppliers to let them know we will have additional requirements of them going forward.  We have never had to request this type of information from them before, and I am unsure of where to start. 

 

Being that our product, as well as the raw materials, can be considered low-risk, would a certificate of conformance stating that the supplier is sending product that conforms to the specifications enough to satisfy the requirement for raw material (2.3.2)?  And would we just need to request the certificates from our suppliers of resin, or would we really need to include the ink and corrugate suppliers as well?

 

Any advice would be appreciated as this whole process is an entirely new one to me! :helpplease:

 

 


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#2 sarah2014

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Posted 13 July 2016 - 04:00 PM

for SQF you have to include all your raw material suppliers and do a risk assessment for each one.

high, medium and low .

 

first ask for their self assessment questionnaire or make one and ask your supplier to fill it out 

 

 ask them to provide you any Certifications, FDA Registrations, Food Associated Certificates and relevant Manufacturer Quality Documents (i.e. NSF, Quality Manual, ISO, Procedure Index, Org. Chart .. etc.

so they can show that they have a system in place .


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#3 Charles.C

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Posted 13 July 2016 - 04:58 PM

Hi sarah,

 

The next question will logically be -

 

What are the criteria for specifying as to whether the supplier is H/M/L risk ?


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Kind Regards,

 

Charles.C


#4 hbrannan

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Posted 13 July 2016 - 06:08 PM

Thank you both for the quick response.  Before we send our current suppliers through the supplier approval process, I planned to get their product specifications on file, and get them to start sending the COC's/COA's. We already have history with our material suppliers, some of them a very long history, so we know they're proven as far as logistics, but I do plan on sending them a questionnaire to fill out so we can have an idea of their current in house systems.  Those that do not wish to send us this information will obviously be considered a higher risk supplier than others, and will not be our first pick as far as purchasing.  This I plan to do for all of our suppliers.

 

I guess my other question would be who needs to send us the COC's/COA's?  Is this also based on the ultimate risk to the product and consumer?  I'm trying to decide if we should request these certificates from all suppliers (including the inks and corrugate packaging) or just the resin suppliers.  Our raw materials all consist of product that do not contain allergens or threat of microbiological pathogens or growth.  The resins and inks are put through a high-heat environment due to the manufacturing process, which also includes metal detection and QC checks every hour.  We do not have any CCP's.   Based on these, we consider our product to be low-risk - we had an SQF pre-audit assessment where the auditor agreed the product was low-risk. 

 

I apologize if any of this is not too clear, I've been muddling through this for a while and no one at this company has had any experience with FS schemes.


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#5 sarah2014

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Posted 13 July 2016 - 06:44 PM

i ask for both of them. COA has more details about the batch. any documents that you can use to convince the auditor that you are ordering safe raw material from approved vendor 

 

my question is 

 

how come you dont have any CCP and you guys  are using a metal detection ?

 did you use the codex for haccp ?


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#6 ncorliss

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Posted 26 July 2016 - 06:57 PM

We request COA's, COC's from all of our suppliers. Even our carton supplier. That falls under my "better to have it and don't need it, than need it and don't have it." Most companies should be used to these requests and shouldn't have a problem providing. My SQF and FDA auditors have only been interested in anything that contacts food. The product and any carton liners. Since we are regulated by the FDA we request the CFR code deceleration including sub clauses and conditions of use. Because of the industry we are in, we also have a list of standard document requests including statements on: Coneg, Conflict Minerals, Country of Origin, Deceleration of Animal Derived Materials, Presence of BPA, Toxins in packaging, Allergen ingredients, Chemicals listed in Prop 65.

 

In addition, we also do not have any CCP's. We use metal detectors in the raw pellets at our injection molding presses. Based on subsequent processing and the risk of loose metal getting in to the product, we didn't determine a CCP was necessary. 


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#7 hbrannan

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Posted 26 July 2016 - 07:12 PM

Ncorliss, thank you for the input - this is what we determined as well as far as the metal detecting and molding processes.

 

I also agree on the "better to have it..." stand.  I would hate to miss that one supplier that the auditor zeros in on and have us gain a NC because of it.  Since my original post, I have requested these documents from our suppliers with much success, I'm happy to say.  I have nearly all specifications on file, and all are happy to begin sending us their COA's and COC's with each shipment. 


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#8 SQFconsultant

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Posted 13 September 2016 - 01:48 PM

Get as much as you can from your suppliers and to determine if your company is low or high risk you can look this up in the SQF Code V7.2 (8.0 coming soon) manual that is available for free at www.sqfi.com 


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Warm regards,

 

Glenn Oster

 

SQF Registered Consultant - Certified for 29 FSC's

Serving clients in: USA, Costa Rica, Panama & Caribbean Islands

International Toll-Free: 800-546-1452

 

http://www.linkedin.com/in/getgoc

 

www.GlennOsterConsulting.com


#9 Charles.C

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Posted 13 September 2016 - 08:56 PM

Get as much as you can from your suppliers and to determine if your company is low or high risk you can look this up in the SQF Code V7.2 (8.0 coming soon) manual that is available for free at www.sqfi.com 

 

Hi SQF consultant,

 

In theory i agree with you.

 

In practice, SQF's presentation, IMO, is frequently a quagmire. For example -

 

http://www.ifsqn.com...ss/#entry105159


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Kind Regards,

 

Charles.C





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