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Vendor Requirements For Raw Materials and Packaging

Vendor Requirements

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#1 jportz

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Posted 12 April 2017 - 02:04 PM

I'm am looking for some advice or information on how to handle vendor's who won't fill out our questionnaire's.  As part of our vendor approval program and the new FSMA requirements we started sending out a questionnaire to our vendors that asks about their food safety programs and hazards in their product and if they control them on their end or to list them so we can ensure we are controlling them.  A lot of our packaging vendors say that most of these questions do not apply to them.  Some of our Ingredient supplier's are flat out refusing to fill out the questionnaire and say it is their policy not to fill out questionnaire's.  Are other people having this same problem and if so what do you do?  We get a lot of requests from out customers and always fill them out and I don't understand how other companies can refuse to fill them out.  We are a small company and can't just switch vendors because they refuse to fill out questionnaire's.  I'm confused on what most people require from packaging vendors also.  We have a vendor that we buy barrel bags from that are food contact packaging and they say their bags are made from FDA approved polyethylene resins and ask how food safety documentation applies.  I don't know a lot about the requirements for food packaging and how to answer their question.  Any help would be great.

 

Thank You


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#2 Kellio

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Posted 12 April 2017 - 04:43 PM

My advice to you is when you send these requests, fill out a NCR (Non-Conformance Report) and/or CAPAR (Corrective Action and Preventive Action Report) when there is no compliance. Document and maintain records of their NCR for FDA Inspections. I would quote the standards and regulations.( for example 21 CFR Subpart G and sections) Start documenting these suppliers and move them to high risk suppliers if they do not comply.  I would send them a instructional letter explaining the regulations and standards and the importance of complying with your company standards and the law. 

 

I hope this helps.


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#3 CMHeywood

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Posted 13 April 2017 - 04:48 PM

Moving a supplier to a high risk status implies that you would do an on-site audit.


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#4 Fishlady

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Posted 13 April 2017 - 06:13 PM

FSMA requirements apply only to "food" as defined in Section 201(f) of the Federal Food, Drug, and Cosmetic Act-

(f)1 The term ‘‘food’’ means (1) articles used for food or drink for man or other animals, (2) chewing gum, and (3) articles used for components of any such article.

 

Packaging is not included.  GFSI supplier requirements include packaging, but FDA requirements do not.  FDA does require traceability of primary contact packaging materials as part of the Bioterrorism Act of 2002.


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#5 Tamale

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Posted 13 April 2017 - 07:41 PM

Fishlady is correct.

 

I work for a food packaging manufacturer of thin wall containers and lids. I will be the first to say that questionnaires are very annoying, every customer has his own and I seem to be constantly renewing one.

 

I would say, be satisfied with asking for certification certificates, not the full audit report, a continuing letter of guarantee and product specs.

 

That should do ok and for vendors they are pretty standard and easy to forward along. When its uncomplicated, everyone is happy!

 

Tamale


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#6 MQA

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Posted 17 April 2017 - 07:25 AM

Appreciate everyone is busy.  Is your questionnaire straight to the point?  Or is it long-winded?  Sometimes supplier questionnaires really are a waste of time.  Questionnaires should be supplied to suppliers that cannot otherwise provide you with the information you require.  Make sure they are short, sweet, with required information only.  Ensure they go to the right person.  

 

Example 1.  Supplier is GFSI-certified and supplies you with finished product specifications, product listing, food safety/quality certificate.  If this supplier has already supplied you with all of your required data, why send them a supplier questionnaire? 

 

Example 2.  A new supplier is in the process of being HACCP-certified.  Supply them the questionnaire and expect it to be completed and returned to you ASAP. 

 

Packaging.

Know what the requirements are food packaging suppliers for your country.  Do you require only a certificate of compliance?  Do you require the product specification?  To what standard must the packaging company abide by? 

 

If you must send out the questionnaire :

Make sure it goes to the right person within the company. 

Again, appreciate everyone is busy and you may not be at top of their priority list

Conduct follow up phone calls/emails

Consider advising the supplier that a second-party site audit shall be conducted should the questionnaire bit be received within a timely manner


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