8 replies to this topic

[Niru]

Hi Everyone,


I am preparing for my BRC audit which will be at the end of this month and I had a question about BRC clause 3.5 Supplier and raw material approval and performance monitoring. We are a Contract Manufacturer (Co-Man) and it is our customers whom source the suppliers and raw material, and packaging we simply assemble their product, fill and package them and send it to their warehouses. Currently I only have a list of all the approved supplier, raw material and packaging, this is to confirm all loads coming in against the specification. The customer has the ultimate responsibility of sourcing approving and performing the monitoring activity, we just let them know if something has deviated upon receipt. Will it be acceptable to say the customer is respsonsible for this entire section and will an auditor be okay with that? I am however aware when it comes to risk assessment the site must still conduct that because the hazards potentially on site and other ingredients can affect the incoming material. I am just more concerned about the approving process and monitoring of the raw materials and packaging.

Thank you,

Niru

[Scotty]

Quote from guidance notes (recently published):

Page 32 'Where raw materials are obtained from a customer-designated supplier(for example, packaging or when contract packing), the site must ensure that information is obtained about the product and supplier such that potential risks to other products are assessed and controlled.'

The company I work for is part of a large group, with a lot of the raw materials being approved from 'group' level. On site we ensure that we have enough information to conduct appropriate assessments and this has been accepted. We recently had our first site v6 audit and no issues were highlighted.

Hope this helps.

Regards

[Niru]

Thank you Scotty, that is very clear.

Quote from guidance notes (recently published):

Page 32 'Where raw materials are obtained from a customer-designated supplier(for example, packaging or when contract packing), the site must ensure that information is obtained about the product and supplier such that potential risks to other products are assessed and controlled.'

The company I work for is part of a large group, with a lot of the raw materials being approved from 'group' level. On site we ensure that we have enough information to conduct appropriate assessments and this has been accepted. We recently had our first site v6 audit and no issues were highlighted.

Hope this helps.

Regards

[Charles.C]

Dear Niru,

The customer has the ultimate responsibility of sourcing approving and performing the monitoring activity, we just let them know if something has deviated upon receipt.

I suggest that, from BRC's POV, you are the producer of the finished product. Rightly or wrongly, the operational responsibility for it's safety can only be with you. QED. For a retail product, this might be called "The Distributor's Nightmare"

Maybe i misunderstand yr post but i find yr current procedure rather bizarre. The implication is that you hv no authority to accept/reject incoming raw material based on yr findings. So yr only corrective action is merely to inform "X" who is seemingly located elsewhere.

I suppose it may depend on the commodity but for fresh food, this scenario seems operationally unworkable unless yr "customer" is located within a few minutes hailing distance / has his/her own monitoring personnel continuously vetting yr performance or the deliverer is willing to hv his product left waiting in limbo (presumably unloaded).

I would suggest that, referring to Scotty's useful post, the key word for you to urgently define with yr "controllers" is "appropriate".

Rgds / Charles.C

[Niru]

Hi Charles,


Sorry I will clarify, as the role of a Co-man we will accept the raw material based on a list which is given to us by the customer. It is the customer's approved supplier list, along with this list we have all the specification. Upon receipt of the raw material we check the specificatoin against the COA, if there are no issues were accept the raw material and proceed with processsing.



At the site level I have grouped incoming ingredients and conducted the risk assessment based on formats. The formats of material we receive from our customers are dry ingredients, liquid ingredients(asepctic, frozen and refrigerated) and ingredients containing allergens. We mostly deal with fruits and vegetable purees, some ytogurts and oats. The way I interpreted the Co-mans role in this process is not to contaminate incoming material at the site, and the customer can be like head office. I suppose the auditor can still ask for supplier evaluation so I better hope my customers have that completed.

Regards,
Niru

Dear Niru,



I suggest that, from BRC's POV, you are the producer of the finished product. Rightly or wrongly, the operational responsibility for it's safety can only be with you. QED. For a retail product, this might be called "The Distributor's Nightmare"

Maybe i misunderstand yr post but i find yr current procedure rather bizarre. The implication is that you hv no authority to accept/reject incoming raw material based on yr findings. So yr only corrective action is merely to inform "X" who is seemingly located elsewhere.

I suppose it may depend on the commodity but for fresh food, this scenario seems operationally unworkable unless yr "customer" is located within a few minutes hailing distance / has his/her own monitoring personnel continuously vetting yr performance or the deliverer is willing to hv his product left waiting in limbo (presumably unloaded).

I would suggest that, referring to Scotty's useful post, the key word for you to urgently define with yr "controllers" is "appropriate".

Rgds / Charles.C

[Charles.C]

Dear Niru,

Thks yr info.

Unfortunately, i remain rather unclear as to what you are actually doing.

Upon receipt of the raw material we check the specificatoin against the COA, if there are no issues were accept the raw material and proceed with processsing.

My query was regarding the corrective action if there are issues ?

Some of yr raw materials look like finished products, eg yoghurt?. I deduce that none of yr inputs require immediate corrective action in the accept/reject context. Lucky for you.

So "processing" = re-packing?

"raw material inspection" = inspecting the labelling of incoming materials for conformance?

Rgds / Charles.C

[Niru]

Evening Charles,


The corrective action will be isolating the raw material in question and putting it on hold. We notify the customer and advise them we are not using it because it was out of spec, where in turn they will go back to the supplier and notify them. The immediate corrective action in these cases is preventing the raw material to go to the manufacturing step, until it has been released by the quality team.


In our case yogurt for smoothies is not a finish product, as it goes through a pasteurization system it kills all the active culture and allows it to be shell stable.


"processing" - manufacturing (customer's ingredients go into customer's packaging, we facility that all of that for them.) In BRC we are section 3.5.4, we are the outsourced processing facility.


raw material inspection = organoleptic, brix, pH, Bostwick and anything else the customer would like us to do for them in addition to our standard testing protocals. As per packaging, the customer provides a certificate of compliance but we also check online during production lot by lot.


I have conducted the risk assessment of the Incoming raw material/packaging internally. What I find challenging is the Allergen surveys can be difficult to obtain from our customer's suppliers as they do not provide that to us in a timely manner.

Regards,

Niru

Dear Niru,

Thks yr info.

Unfortunately, i remain rather unclear as to what you are actually doing.


My query was regarding the corrective action if there are issues ?

Some of yr raw materials look like finished products, eg yoghurt?. I deduce that none of yr inputs require immediate corrective action in the accept/reject context. Lucky for you.

So "processing" = re-packing?

"raw material inspection" = inspecting the labelling of incoming materials for conformance?

Rgds / Charles.C

[Niru]

*Shelf*

In our case yogurt for smoothies is not a finish product, as it goes through a pasteurization system it kills all the active culture and allows it to be shell stable.

[Charles.C]

Dear Niru,

Thks for info. Situation now more clear and logical.

In our case yogurt for smoothies is not a finish product, as it goes through a pasteurization system it kills all the active culture and allows it to be shell stable.

Interesting. I deduce you are purchasing processed, unpasteurised yoghurt and then re-processing, ie pasteurising it. Didn't know anybody did that.

Rgds / Charles.C