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Raw material, supplier and packaging risk assessment (BRC)

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bensmith007

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Posted 13 January 2017 - 07:44 PM

Hello all,

 

Standard- BRC Product- herbs and spices, blends of herbs and spices, powdered beverage mixes Location- USA (but I'm from UK) Practical experience- not much

 

I am currently working on risk assessments for suppliers, raw materials and packaging- attached is the spreadsheet format I am using for the combined assessment for raw materials and suppliers (based on documents found at this forum). We have over 100 suppliers and several hundred products.This is essentially a start-up company as we recently bought a new spice business from a former customer and we are working on all aspects of food safety management, eventually working towards BRC. For now we are just focusing on HACCP/ PRPs/ GMPs and will move onto HARPC/ FSMA compliance later.

 

Some questions- do you think the info I am obtaining is sufficient for RM/ suppliers? If a supplier has GFSI accreditation, can I automatically consider them low risk? Should that judgement be dependent on audit grade where they are given to me? If so, ideas on what the cut off point for low risk would be between the different standards? (so far I have some BRC, some SQF) Any thoughts on my categories for the split of raw materials? Any good links for information on where I can find information on specific risks (e.g. pathogens associated with a group or fraud/ substitution) for these groups (I have the American Spice Trade Assn documents for this info for spices)?

 

For packaging suppliers, I found a reference on this forum to some other questions that could be asked that I wasn't familiar with- for migration certificates, is this something that I can expect my packaging suppliers to have (i.e. is it a legal requirement in the US)? Reference was made to PIGS documentation- what is this? It's not easy to search for this acronym on google! Any other good information to ask for for the packaging risk assessment?

 

Sorry for all of the questions, I hope my spreadsheet template gives a little back, and thanks for all the great advice you contributors give!

 

Ben

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Charles.C

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Posted 13 January 2017 - 11:45 PM

Hi ben,

 

It is arguably more important from a BRC clause perspective to focus on the risk status of the raw material rather than the supplier. But since BRC leaves the risk assessment methodology open i guess this is a just a matter of choice.

 

"Legality" seems to be absent from yr chart ?.

IIRC ASTA offers advice on typical microbial pathogens in spices/herbs ?.

The customary source for fraud data is foodfraud.org but no longer free.

 

PIGS is here -

 

http://www.ifsqn.com...for/#entry90966


Kind Regards,

 

Charles.C


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bensmith007

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Posted 14 January 2017 - 12:47 AM

Thanks Charles,

 

And thanks for the thousands of other posts you have made, you are a good man!

 

Yes I have some info from ASTA specific to herbs and spices, and foodfraud.org has a one week free trial (I think that is new?) so I am saving that for a week when I can concentrate on adulteration and fraud!!!

 

Can you explain what you mean exactly by legality? Would this be a general question as to whether the supplier in question complies with local and US laws, e.g. have filled out the child labor questionnaire if they're outside the US? (Gosh, now I need a lawyer) Or do I have the wrong end of your stick?

 

I guess I am looking at risk in the wrong way- I was thinking that supplier is more important than raw material risk, in that risks such as microbiological will be more or less ubiquitous, but if we buy them from a GFSI certificated supplier then we should feel confident they have been processed or handled in such a way as to minimize the risk from the raw material and we are basically covered by the supplier's due diligence (as evidenced by GFSI certificate). Either way, I was hoping that my document will also capture enough information about RM risks as well, with the sections for micro/ physical/ chemical hazards associated with the RM- or is this not 'strong' enough in your opinion for documenting the risks?

 

Thanks,

 

Ben



Charles.C

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Posted 14 January 2017 - 01:47 AM

Hi Ben,

 

BRC are everywhere in the Standard hoping to cover implicitly/explicitly their interpretation of the scope of "due diligence" in UK.

 

"legality" is in BRC clause 3.5.1.1 and is BRC7 glossary defined as -

In compliance with the law in the place of production and in the countries where the product(s) is/are intended to be sold.

 

BRC refer to "low risk suppliers" in 3.5.1.2 but omit to define what they mean by it !

 

Regarding "risk" in yr last paragraph, i suggest you review the logic flow in clauses 3.5.(1.1 - 1,2) to see the (BRC highly convoluted) point. But, as i said, afaik the exact approach used is totally optional and i think some posters have folowed yr style. I anticipate that BRC don't care as long as the required elements in the Code are covered.

 

i think most of yr queries in last paragraph are addressed directly/indirectly in the post/thread linked below and within my associated excel sheet. i suggest to have a look -

 

.http://www.ifsqn.com...al/#entry100194

 

And thanks yr kind intro. !

 

PS - One classic ref. text for microbial pathogens/food categories is the book "microorganisms in food, vol6,ICMSF but I doubt even they differentiate in great detail regarding different types of herbs/spices


Kind Regards,

 

Charles.C


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