Jump to content

  • Quick Navigation
Photo

Raw Material COA Requirements


  • You cannot start a new topic
  • Please log in to reply
11 replies to this topic

#1 Brian S

Brian S

    Grade - Active

  • IFSQN Active
  • 4 posts
  • 0 thanks
0
Neutral

  • United States
    United States

Posted 27 November 2017 - 02:00 PM

Hello everyone,

 

My company is a small, family operated pasta manufacturer specializing in IQF filled pastas. As a general rule our products are not ready to eat and validated cooking instructions are provided with the labeling. I have been with the company for about 6 months and with other issues aside I am now beginning to work on our supplier approval and coa requirements. As far back as I can tell the company "required coa's for each raw material" yet that has not, and is not, being followed. We work with several distributors which specialize in institutional accounts (restaurants, hospitals, etc.) with us, a manufacturer, being the exceptions. Because of that I am having a hopelessly hard time getting coa's for all of the raw materials.

 

I am putting together a system in which raw materials which carry a reasonable or foreseeable hazard will be tested by a third party lab. My question for all of you is whether or not there are certain raw materials that you don't require a coa or in-house testing for because the hazard is not reasonable. On my list I have a few spices (garlic, sugar, onion powder, etc.), tomato puree and paste because of the ph, and a few hard cheeses which according to the literature, do not support micro activity. I also have a risk assessment for each material which would, in my mind, mitigate a need for testing. 

 

Thanks



#2 Peter C.

Peter C.

    Grade - Active

  • IFSQN Active
  • 18 posts
  • 4 thanks
2
Neutral

  • United States
    United States

Posted 27 November 2017 - 10:07 PM

Hi Brian,

     Below is the wording in FSMA, which I presume may be why you are looking to complete a hazard analysis. 

 

“The hazard analysis must consider hazards that may be present in the food because they occur naturally, are unintentionally introduced, or are intentionally introduced for purposes of economic gain."

 

"We continue to believe that hazards that may be intentionally introduced for economic gain will need preventive controls in rare circumstances, usually in cases where there has been a pattern of economically motivated adulteration in the past."

 

     As such you should consider Food Fraud as part of your hazard analysis and not just microbiological contamination. Food Fraud is the intentional misrepresentation of a food for the purposes of economic gain by the seller. There are hundreds of examples where the adulterant is hazardous and consumers are affected. Spices are one of the most commonly adulterated foods because it is relatively easy to mix with other materials and they are high value. In addition, keep in mind that the people who are selling fraudulent food are trying not to get caught so your mitigation plan may need to incorporate more than requiring a C of A and potentially more than just testing (unless your confident that testing will detect the fraud). 

 

Best Regards,

Peter



#3 FurFarmandFork

FurFarmandFork

    QA Manager/FS Blogger

  • IFSQN Fellow
  • 1,001 posts
  • 463 thanks
68
Excellent

  • United States
    United States
  • Gender:Male
  • Location:USA

Posted 28 November 2017 - 12:37 AM

Hello everyone,

 

My company is a small, family operated pasta manufacturer specializing in IQF filled pastas. As a general rule our products are not ready to eat and validated cooking instructions are provided with the labeling. I have been with the company for about 6 months and with other issues aside I am now beginning to work on our supplier approval and coa requirements. As far back as I can tell the company "required coa's for each raw material" yet that has not, and is not, being followed. We work with several distributors which specialize in institutional accounts (restaurants, hospitals, etc.) with us, a manufacturer, being the exceptions. Because of that I am having a hopelessly hard time getting coa's for all of the raw materials.

 

I am putting together a system in which raw materials which carry a reasonable or foreseeable hazard will be tested by a third party lab. My question for all of you is whether or not there are certain raw materials that you don't require a coa or in-house testing for because the hazard is not reasonable. On my list I have a few spices (garlic, sugar, onion powder, etc.), tomato puree and paste because of the ph, and a few hard cheeses which according to the literature, do not support micro activity. I also have a risk assessment for each material which would, in my mind, mitigate a need for testing. 

 

Thanks

Hi Brian,

 

It seems like you're following the standard approach of determining what actually needs testing indicated on the CoA. Did you have a specific question about your proposed system?


QA Manager and food safety blogger in Oregon, USA.

 

Interested in more information on food safety and science? Check out Furfarmandfork.com for more insights!

Subscribe to have one post per week delivered straight to your inbox.

 


#4 Brian S

Brian S

    Grade - Active

  • IFSQN Active
  • 4 posts
  • 0 thanks
0
Neutral

  • United States
    United States

Posted 28 November 2017 - 12:19 PM

Thanks for your input

 

I think at the end of the day I am wondering if you some raw materials just may not need coa's or testing. For instance, the semolina that we are using ends up being fully cooked, there is no documented incidents of economic fraud that I can find, and a risk assessment based on the material and supplier would suggest that physical and chemical hazards are not likely. Based on this I would argue that a visual inspection by my receivers is sufficient for verification. However I have worked for companies where the coa was imperative regardless of risk and every board on this site seems to suggest that others view it the same way. 



#5 Peter C.

Peter C.

    Grade - Active

  • IFSQN Active
  • 18 posts
  • 4 thanks
2
Neutral

  • United States
    United States

Posted 28 November 2017 - 02:59 PM

As an FYI, using the food fraud database www.foodfraud.org I was able to find two records for semolina adulteration from 2007 and 2009. It is very common to be surprised at the amount of food fraud that goes on. It is critical to ensure the data that one uses to drive decisions is as robust as possible so as not come to the wrong conclusion. 

 

 

 

Best regards,

Peter



#6 FurFarmandFork

FurFarmandFork

    QA Manager/FS Blogger

  • IFSQN Fellow
  • 1,001 posts
  • 463 thanks
68
Excellent

  • United States
    United States
  • Gender:Male
  • Location:USA

Posted 28 November 2017 - 08:04 PM

Thanks for your input

 

I think at the end of the day I am wondering if you some raw materials just may not need coa's or testing. For instance, the semolina that we are using ends up being fully cooked, there is no documented incidents of economic fraud that I can find, and a risk assessment based on the material and supplier would suggest that physical and chemical hazards are not likely. Based on this I would argue that a visual inspection by my receivers is sufficient for verification. However I have worked for companies where the coa was imperative regardless of risk and every board on this site seems to suggest that others view it the same way. 

Gotcha.

 

No, not every item needs a CoA. Every item does need a specification that you can receive it against. Sometimes those specifications include "free of e. coli" or some other organism, and you can verify that specification by testing the product yourself or receiving a CoA. But everything is evaluated based on it's individual risk as an ingredient.

 

I think semolina would have the following requirements in it's specification:

1. Type of pasta (e.g. shape) percent broken pieces, etc.

2. microbial results I wouldn't require if indeed you aren't treating it as RTE and plan on putting it through a validated kill step

3. Since I assume shelf stable, perhaps a moisture specification verified again by either CoA or your own testing

 

If ultimately you decide that moisture isn't an issue with the product and you are just inspecting for broken pieces, correct product, any obvious contamination, then there's no reason they would send you a CoA. You would have a spec and/or letter on file saying what it is and that it's all produced legally. In the same way I might buy canned carrots as an ingredient, I'm not going to require micro results CoA if it's per specification retorted. I will instead to an inspection of the pop-up seals and/or can seals to make sure the packaging was intact.


QA Manager and food safety blogger in Oregon, USA.

 

Interested in more information on food safety and science? Check out Furfarmandfork.com for more insights!

Subscribe to have one post per week delivered straight to your inbox.

 


Thanked by 1 Member:

#7 Charles.C

Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 13,607 posts
  • 3732 thanks
410
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 29 November 2017 - 08:31 AM

Hi Brian,

 

i agree with  3F's initial sentences but i would also add that a safety oriented spec. may be different to a quality (non-safety related) one.

 

You hv not mentioned yr technical background or what specific purpose yr COA is immediately intended for ? FS Private Standard, FSMA etc etc ?

 

Are you familiar/experienced with haccp ? I ask because the Product Specification is a typical (haccp 101) initial requirement to conducting a hazard analysis.


Kind Regards,

 

Charles.C


Thanked by 1 Member:

#8 BrummyJim

BrummyJim

    Grade - SIFSQN

  • IFSQN Senior
  • 329 posts
  • 116 thanks
25
Excellent

  • United Kingdom
    United Kingdom
  • Gender:Male
  • Location:South West
  • Interests:Motorbike gone now. Only the dog to walk!

Posted 29 November 2017 - 11:39 AM

Hi Brian,

 

Unfortunately hard cheeses can support micro activity. I worked for a micro lab where we found spore forming bacteria in a well know Spanish hard cheese.



#9 Brian S

Brian S

    Grade - Active

  • IFSQN Active
  • 4 posts
  • 0 thanks
0
Neutral

  • United States
    United States

Posted 29 November 2017 - 02:02 PM

Thanks for all the input. To answer your question Charles I have specs and supplier safety programs on file and that is how I completed the initial hazard analysis for all of our raw materials and packaging. My hazard analysis concluded that in light of the reasons given above, semolina is not a high risk material form a food safety or quality standpoint. In my opinion a coa is not necessary. For other raw materials like ricotta cheese for instance, there is no validated kill step so my hazard analysis includes a coa requirement for micros per lot. I think Fork answered my question despite how poorly I was asking it. Arbitrarily demanding coa's for products which do not carry food safety or quality risk may not be necessary.



#10 Charles.C

Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 13,607 posts
  • 3732 thanks
410
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 29 November 2017 - 07:00 PM

Thanks for all the input. To answer your question Charles I have specs and supplier safety programs on file and that is how I completed the initial hazard analysis for all of our raw materials and packaging. My hazard analysis concluded that in light of the reasons given above, semolina is not a high risk material form a food safety or quality standpoint. In my opinion a coa is not necessary. For other raw materials like ricotta cheese for instance, there is no validated kill step so my hazard analysis includes a coa requirement for micros per lot. I think Fork answered my question despite how poorly I was asking it. Arbitrarily demanding coa's for products which do not carry food safety or quality risk may not be necessary.

Hi Brian,

 

Depending on the FS Standard, the requirements/options/benefits involving COA can sometimes be non-simple -

 

For example, from SQF Code/Guidance and BRC respectively -

 

2.4.5.1  Raw   materials,   ingredients,   packaging materials,  and  services  that  impact  on  finished product  safety  shall  be  supplied  by  an  approved supplier.

 

2.3.2.4  Raw    and    packaging    materials    and ingredients  shall  be  validated  to  ensure  product safety  is  not  compromised  and  the  material  is  fit for   its   intended   purpose.  Validation   of   raw materials  and  ingredients  shall  include  Certificate of  conformance;  or  certificate  of  analysis;  or sampling and testing. 

 

The supplier [manufacturer] must require their material suppliers to verify they are complying with specifications for the products supplied. The  methods  of  analyses  must  conform  to  recognized  industry  standards  (refer  2.5.6).

---------------------------------------------------------------------------------------------------------------------------------------
The company shall have a documented procedure for the acceptance of raw materials and packaging on receipt based upon the risk assessment (clause 3.5.1.1). Raw material including packaging acceptance and its release for use shall be based on one or a combination of:
•  product sampling and testing
•  visual inspection on receipt
•  certificates of analysis – specific to the consignment
•  certificates of conformance.
 


Kind Regards,

 

Charles.C


Thanked by 1 Member:

#11 imadoughguy

imadoughguy

    Grade - MIFSQN

  • IFSQN Member
  • 51 posts
  • 12 thanks
4
Neutral

  • United States
    United States
  • Gender:Male
  • Location:Orlando, Florida
  • Interests:Building Redemptive Relationships, Self Improvement, Cars, Fishing, Home Improvement, Serving Others and Seeing Positively Impacted People in my Wake. :-)

Posted 29 May 2018 - 01:13 PM

Yes, it's true the SQF Code does state that Validation shall include COC, COA, or sampling testing etc.

 

Validation, in SQF Code, is typically a higher level of review done annually; Verification is something done perhaps daily or weekly.

 

My question is do we have to Validate the COA, COC, etc... each time we receive a material (which feels like a Verification to me), or on a regular basis like quarterly or annually?

 

 

Thanks

Phil



#12 Scampi

Scampi

    Grade - FIFSQN

  • IFSQN Fellow
  • 1,307 posts
  • 371 thanks
67
Excellent

  • Canada
    Canada
  • Gender:Not Telling

Posted 29 May 2018 - 01:26 PM

I wouldn't validate COA every time a material comes in unless your RA shows it as high risk

 

The whole idea behind the COA is that it is a legally binding contract. If the seller says 0.00 e coli and you randomly sample and get a positive hit, boom product goes back, and gets replaced

 

However, if you determine low risk, then the COA will suffice and you may simply want to randomly sample yearly/quaterly etc based on risk as your actual validation as part of your HACCP review



Thanked by 1 Member:



1 user(s) are reading this topic

0 members, 1 guests, 0 anonymous users