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Supplier Risk Assessment Records 3.6.3


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#1 Paul Hill

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Posted 20 February 2017 - 01:11 PM

Ho Hum!

 

We have had BRC global packaging and packaging films accreditation for over 8 years, for the first time in 7 years we employ a pre auditor (serves me right?) he raises 15 minor non conformity's, one of which is our lack of supplier assessment records 3.6.3, problem is all of this is controlled by our head office based elsewhere, would they be classed as a sub contractor? and any help with raising an assessment sheet would help?

 

kindest regards

Paul


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#2 Foodworker

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Posted 20 February 2017 - 08:14 PM

A head Office should not be a sub-contractor, although I did come across one major multinational where many of the different functions- Purchasing, Transport/Distribution etc., were separate companies within the same group and could be thought of as sub-contractors. 

 

Even if your supplier approval is carried out by your Head Office, it should still be audited as part of your certification. The question then is how to audit it.

 

It can be covered by a separate visit to the Head Office. This is fairly common for companies with several manufacturing sites and a Head Office which undertakes activities within the Standard. It will of course mean extra cost.

 

Alternatively it can be audited by making available the staff responsible for the process and all the records on your site, or sometimes remotely if effective communication links can be set up. You would need to plan and agree this with your Certification Body in advance.

 

What is not acceptable is to say it is not applicable as it is a Head Office function.

 

How did you do it in your previous audits?

 

Your pre-auditor therefore may be correct, although if no records at all were available, it should have been a Major and you would probably have picked up a couple more in the other clauses of this section.

 

Personally I think 15 non conformities in a pre-audit is good going and in fact helpful. It is much better to have them in pre-audit where you can deal with them in your own time frame than in your certification audit.


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#3 Paul Hill

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Posted 21 February 2017 - 08:04 AM

Hi Foodworker,

 

Thank you for your speedy reply, many of the problems we encounter are due to being a small company and of a limited size, I am unsure why this has not raised non conformities previously, it has been discussed but,.........

 

Our head office does not have accreditation, turning on my one brain cell for 'just a minute', would it be more advantageous to create purchasing of the products used (granule, ink, cardboard tubes, solvent & masterbatch) in house?, to have our own suppliers and follow the requirements of the standard that way?

 

If not and with the limited time prior to the next audit, one would guess from your suggestion that we will be getting our first major non conformity?

 

Once again thank you for your help

 

Kind regards

Paul


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#4 Foodworker

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Posted 21 February 2017 - 10:22 AM

Depending upon how your company is set up, it may be possible to distinguish between 'purchasing', ie the financial management of suppliers carried out at a Head Office, and the 'Supplier Approval/Monitoring' ie the material safety management of suppliers which could be carried out by the manufacturing site.

 

This section of the Standard does not use the word 'purchasing' anywhere.

 

Is yours the only manufacturing site? If not some of the other sites may already have the information that you need.

 

Otherwise, the site (ie you!) would need to establish your own procedures and records to demonstrate compliance with the SOI and clauses. That in itself is not too hard, but difficulties may arise with your Head Office colleagues if your information indicates that the supplier shouldn't be used.

 

Looking at your materials, it is not very likely that many, if any, would be GFSI certified, so you would need to establish your own criteria and methods, which in all probability would be a Supplier Questionnaire approach. Carrying out your own supplier audits is not likely to be practicable logistically and before your audit. 


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#5 Paul Hill

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Posted 21 February 2017 - 12:14 PM

Strangely all but one of our suppliers supply product which is suitable for food contact, this was a pre-curser when we set up the companies policy, I have up to date certificates to confirm this, we do have supplier self audits which suppliers are required to complete, normally pre-audit, we also have a list, albeit it we only use 5 suppliers and have used the same ones for 10 years.

 

I have amended our own policy and will let you know the outcome of our audit,

 

We are the only site

 

GFSI was established to ensure confidence in the delivery of safer food to consumers, while continuing to improve food safety throughout the supply chain.  These global standards address food, packaging, packaging materials, storage and distribution for primary producers, manufacturers and distributors.

 

I thank you for your valued assistance and it has given me some confidence in removing the possibility of gaining a major non-conformance, I can live with minor... hahaha!

 

Kind Regards

Paul


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