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Are we obligated to provide customers with suppliers HACCP manual?

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CathyS

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Posted 19 June 2018 - 06:48 PM

The company I work for is a slitter/converter of unprinted food contact plastic packaging films.  We are not the manufacturer of the products we convert.  Some of the films purchased are imported from overseas. 

 

We do not have a FSVP.  The FDA has extended the compliance date of importers of food contact substances to conform with FSVP regulations to May, 2019 for further consideration.  All our suppliers are selected, evaluated and maintained based on their ability to meet FDA compliance, completion of a Supplier Self-Assessment, Letter of Continuing Guarantee, COAs or COCs and the ability to meet specifications.

 

Our customer is requesting a copy of our FSVP.  I referred them to the FDA guidance document regarding the extension and explained we have an Approved Supplier Program.  They are now requesting a copy of our suppliers HACCP manual.  Are we obligated to provide the customer with this information?   Isn’t our assessment of the supplier good enough? 

 

Your comments are appreciated.  



Scampi

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Posted 19 June 2018 - 08:32 PM

No, you are under zero obligation, however, you run the risk of losing that customer


Please stop referring to me as Sir/sirs


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sqflady

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Posted 22 June 2018 - 12:15 PM

Agree with Scampi.  If any vendor will not provide the documents we request, we will find a different vendor that will provide them.  I would suggest that you create your own HACCP plan that you share with the customer.  



CathyS

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Posted 22 June 2018 - 04:41 PM

The customer was given a copy of "our" HACCP manual.  They did not accept it as we are not the manufacturer of the product.  



mgourley

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Posted 23 June 2018 - 02:15 AM

Given the OP, I'll be a little contrarian here.

You are absolutely not obligated to provide your customers with your suppliers HACCP manual.

If they want it so badly, they should directly ask for it from your supplier.

 

Sometimes these things are provided to you with NDA's in place, or at least a general trust that you do not randomly share these things with other parties.

 

Marshall


Edited by mgourley, 23 June 2018 - 02:18 AM.




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