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#1 clrmwebb4350

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Posted 08 May 2017 - 02:10 PM

My question relates to long term raw material suppliers (legacy suppliers). As part of our approved supplier program we approved long term material suppliers based on history, lack of food safety issues, and delivery history. On our last SQF audit we were found to be non-compliant in this area. Part of our corrective action was to send an audit to the suppliers and ask food safety questions, such as do they have an established quality programs, pest control program etc.  Only a few suppliers have responded and several have flat out told me they do not complete these type of surveys do to the volume they receive.

 

As a result of this I need to come up with a different way to evaluate the suppliers. What kind of programs do others have in place?

 

We are a food packaging company that produces food grade valves, covers, and such that have direct and in-direct food contact. All of our suppliers are material suppliers not ingredients.    

 

Thank you in advance for all suggestions! 

 

 

 

Best regards,

Chris


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#2 ctzinck

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Posted 08 May 2017 - 02:12 PM

would it be possible to go audit them in person?


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#3 clrmwebb4350

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Posted 08 May 2017 - 02:29 PM

Hi. Thank you for your response. Unfortunately no. I have thought about testing materials monthly what I am not sure what I test them for. The FDA letter and other documentation states what CFR the material is approved for.  

 

 

Chris


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#4 FurFarmandFork

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Posted 08 May 2017 - 03:15 PM

SQF is really annoying with supplier approval. According to the code and guidance technically you get to define what criteria a supplier is approved under and you are only held accountable to following your own criteria, reviewing those criteria annually, and demonstrating through product quality history that you've verified those suppliers are still acceptable at some interval.

 

In practice, an actual supplier audit is industry standard and easy for CB's to audit against, and because it's so common they aren't used to having to think about your unique program, which often leads to "that sounds like BS so here's a minor".

 

It's really auditor dependent.

 

 food grade valves, covers, and such that have direct and in-direct food contact

 

 

 

Here's what I'd do since pretty much all your "ingredients" fall under the same category. Do a detailed risk assessment of the chemical, microbiological, and physical hazards inherent to the materials, and describe how you control each of them through material composition, inspection, process etc. Then, type up a summary of how a "bad" supplier could actually affect these issues and limit "supplier approval" to collecting basic information like current contact info and a letter of guarantee ("I won't sell you anything dangerous or illegal and to the best of my knowledge it's okay to use in food processing equipment").

 

It's typically easy to maintain a register of contact info and have them simply sign a form letter, and if you've got a thorough risk assessment covering the risks, and the info you havedecided to collect is current on all suppliers, you should be able to get through the requirement.

 

One thing I see in your post that may have caused the auditor pause is that you approved them based on "delivery history". If you can show documentation that demonstrates you re-evaluate delivery history periodically as a metric that typically works, but usually this results in SQFP's saying something like "we haven't had issues with them", which is kind of a cop-out.

 

Dazzle them with paperwork and metrics on how many defective/late/unusable products each supplier has sent you in the past year, and it will demonstrate that you are actually auditing suppliers based on delivery history.


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#5 clrmwebb4350

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Posted 08 May 2017 - 03:42 PM

Thank you for your response. We have a detailed "risk assessment of the chemical, microbiological, and physical hazards inherent to the materials, and describe how you control each of them through material composition, inspection, process etc." We accessed each supplier and did a risk analysis and assigned a "risk" number to them.

 

We receive a COC or COA with each shipment. However, we do not request a letter of guarantee so maybe that is one solution. 

 

We also annually review our suppliers for food safety events, quality issues, and on time delivery. I have detailed records of the review signed by our purchasing manager and myself. 

 

We had all this in place and still received a minor on the audit. I am tasked with coming up with a solid corrective action plan. I did receive a few completed audits from some suppliers and any new suppliers must complete the audit before we will purchase materials from them.

 

We can conduct visual inspections of material when it comes in looking for evidence of contamination and I like the idea of a letter of guarantee.  

 

 

 

Thanks,

Chris


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#6 FurFarmandFork

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Posted 08 May 2017 - 03:47 PM

Thank you for your response. We have a detailed "risk assessment of the chemical, microbiological, and physical hazards inherent to the materials, and describe how you control each of them through material composition, inspection, process etc." We accessed each supplier and did a risk analysis and assigned a "risk" number to them.

 

We receive a COC or COA with each shipment. However, we do not request a letter of guarantee so maybe that is one solution. 

 

We also annually review our suppliers for food safety events, quality issues, and on time delivery. I have detailed records of the review signed by our purchasing manager and myself. 

 

We had all this in place and still received a minor on the audit. I am tasked with coming up with a solid corrective action plan. I did receive a few completed audits from some suppliers and any new suppliers must complete the audit before we will purchase materials from them.

 

We can conduct visual inspections of material when it comes in looking for evidence of contamination and I like the idea of a letter of guarantee.  

 

 

 

Thanks,

Chris

 

 

....it sounds like you're doing everything the code requires. Honestly I'd challenge it based on what you provided. If you've effectively controlled the risks then the suppliers are "audited" sufficiently to protect food safety. And working in food, no auditor has ever made me do a review of the pest control procedures for our sanitizer supplier for example.

 

Don't be afraid to push back if you're meeting the code, the auditor's personal opinion isn't what your certification is for.


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#7 SQFconsultant

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Posted 08 May 2017 - 08:23 PM

You have good grounds for challenging the Auditor's finding even after the Auditor left the facility. Just directly contact the CB and inform them you don't agree with the finding. Ask the non-con be held in suspense and prove your compliance with the code was already in place prior to the audit finding.

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#8 Heidi_SQF

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Posted 16 May 2017 - 05:15 PM

I agree that it sounds like you are meeting the code.  Make sure your Approved Supplier Procedure states what you are doing to meet the code. 

 

We sent our supplier questionnaire to our "legacy suppliers" explaining that we were moving to a new standard and this was part of the requirement.  We pushed back to the suppliers that were hesitant to fill it out explaining that they would no longer be considered an approved supplier and would be dropped from our list if they were found non-compliant. 

 

A lot of standards are moving in the direction of on-site audits or questionnaires so if they aren't happy with the volume, it isn't going away....there's only going to be more. 

 

Good luck with all this!


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#9 Charles.C

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Posted 17 May 2017 - 11:25 AM

My question relates to long term raw material suppliers (legacy suppliers). As part of our approved supplier program we approved long term material suppliers based on history, lack of food safety issues, and delivery history. On our last SQF audit we were found to be non-compliant in this area. Part of our corrective action was to send an audit to the suppliers and ask food safety questions, such as do they have an established quality programs, pest control program etc.  Only a few suppliers have responded and several have flat out told me they do not complete these type of surveys do to the volume they receive.

 

As a result of this I need to come up with a different way to evaluate the suppliers. What kind of programs do others have in place?

 

We are a food packaging company that produces food grade valves, covers, and such that have direct and in-direct food contact. All of our suppliers are material suppliers not ingredients.    

 

Thank you in advance for all suggestions! 

 

 

 

Best regards,

Chris

 

Hi Chris,

 

I have an ultra-simple query -

 

Why were you found non-compliant ?

 

This IMEX dictates what you (minimally) have to do next.


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Kind Regards,

 

Charles.C


#10 clrmwebb4350

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Posted 17 May 2017 - 11:53 AM

Finding:

 

The Standard:

The approved supplier program shall be based on the prior performance of a supplier and the risk level of the raw materials ingredients, packaging materials, and services supplied, and shall contain as a minimum agreed specifications, reference to the rating of the level of risk applied to a raw material’s ingredients, packaging materials and services and the approved supplier, a summary of the food safety and quality controls implemented by the approved supplier, methods for granting approved supplier status,  methods and frequency of monitoring approved suppliers, details of the certificates of conformance if required, methods and frequency of reviewing approved supplier performance and status.                                                                                                      

The Finding:
The auditor found during the review of the Supplier Approval Program that the facility could not provide supporting documentation for the approval status for some of the suppliers selected.                                                                                                                                              

The Evidence:
The facility maintains a Incoming Goods and Services Program, 06/25/13, which outlines the criteria for selecting and approving suppliers; however, during the review of the approval documents for 3 of the legacy suppliers, the auditor found that the approval status of the suppliers was based on the supplier’s history of supplying safe materials.  Both the Standard and the plant’s Supplier Approval Program requires that a summary of food safety controls and review of the controls to ensure meet the food safety requirements must also be done to grant approved status.  For these suppliers, the plant has not completed those requirements.   


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#11 Charles.C

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Posted 17 May 2017 - 12:55 PM

Finding:

 

The Standard:

The approved supplier program shall be based on the prior performance of a supplier and the risk level of the raw materials ingredients, packaging materials, and services supplied, and shall contain as a minimum agreed specifications, reference to the rating of the level of risk applied to a raw material’s ingredients, packaging materials and services and the approved supplier, a summary of the food safety and quality controls implemented by the approved supplier, methods for granting approved supplier status,  methods and frequency of monitoring approved suppliers, details of the certificates of conformance if required, methods and frequency of reviewing approved supplier performance and status.                                                                                                      

The Finding:
The auditor found during the review of the Supplier Approval Program that the facility could not provide supporting documentation for the approval status for some of the suppliers selected.                                                                                                                                              

The Evidence:
The facility maintains a Incoming Goods and Services Program, 06/25/13, which outlines the criteria for selecting and approving suppliers; however, during the review of the approval documents for 3 of the legacy suppliers, the auditor found that the approval status of the suppliers was based on the supplier’s history of supplying safe materials.  Both the Standard and the plant’s Supplier Approval Program requires that a summary of food safety controls and review of the controls to ensure meet the food safety requirements must also be done to grant approved status.  For these suppliers, the plant has not completed those requirements.   

 

Hi Chris,

 

Thks for above.

 

I note that you can modify yr own requirements but not those of the Standard's clauses.

I note that the "history, lack of food safety issues, and delivery history" in OP is seemingly mismatched to the Standard's requirements for numerous items stated in Post 10.

 

I deduce certain suppliers are not supplying info. as per red requirements due to either (a) on Principle, ie they will never respond under any circumstances or (b) willing to respond but yr requested info. is difficult for them to respond to due to XYZ, eg too lengthy, too difficult [for them], whatever. (My guess is both the previous).

 

If the reason is (a) only one (obvious) option appears to exist.

 

If the reason is (b) it may relate to format /what is included/requested in yr referenced program 06/25/13. Any feasible changes which can be suggested here will then presumably depend on the details of the existing program (i guess this is esssentially what you refer to in "corrective actions" of OP). Is it possible to post this document or summarize its contents ? (or perhaps list the "corrective actions" if such are about to become the revised program).

 

JFI, when BRC focused on raw material suppliers in the BRC Food Standard, the first frequent response was a request from such suppliers to their customers to provide a suitable format. It's a valid FS requirement but a long-existing headache for both parties to fully comply.


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Kind Regards,

 

Charles.C


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#12 clrmwebb4350

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Posted 17 May 2017 - 01:19 PM

Charles C,

Thank you for your response. After requesting multiple times, I actually have  most of my supplier surveys complete. Unfortunately the biggest supplier has refused to comply and they supply multiple materials from multiple manufacturers. Because the manufacturers are chemical companies opposed to food ingredients, I believe they are just not used to completing documentation or do not think it applies to them. I have considered shortening the form but it is already pretty concise and only covers basic questions such as pest control, lot tractability, ect.

 

I may resort to annual testing and QA inspections as an alternate qualification on the suppliers that did not complete the survey. All others have been reviewed, assessed and signed off as approved.  

 

Thanks again for everyone's responses :-)


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#13 Charles.C

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Posted 17 May 2017 - 01:28 PM

Charles C,

Thank you for your response. After requesting multiple times, I actually have  most of my supplier surveys complete. Unfortunately the biggest supplier has refused to comply and they supply multiple materials from multiple manufacturers. Because the manufacturers are chemical companies opposed to food ingredients, I believe they are just not used to completing documentation or do not think it applies to them. I have considered shortening the form but it is already pretty concise and only covers basic questions such as pest control, lot tractability, ect.

 

I may resort to annual testing and QA inspections as an alternate qualification on the suppliers that did not complete the survey. All others have been reviewed, assessed and signed off as approved.  

 

Thanks again for everyone's responses :-)

 

Hi Chris,

 

You may be being too generous to chemical Companies.

 

Indeed my guess is that one consequence of BRC's expanded requirements has been a windfall for 3rd party inspection companies.

 

How Internal QA costs/audits (shocks ??) vs external handling balances out obviously financially relates to volume of business. From a strictly FS POV it's hardly debatable IMO.

 

PS - I'm still wondering what "lot tractability", "ect" means. :smile:


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Kind Regards,

 

Charles.C


#14 clrmwebb4350

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Posted 17 May 2017 - 01:51 PM

Charles C,

Lol.. have to love typos... they at least make us laugh :-) 

 

Thanks and have a great day!


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