10 replies to this topic

[mgourley]

3.5.1.2

The company shall have a documented supplier approval and ongoing monitoring procedure to ensure that suppliers are manufacturing products under hygienic conditions, effectively manage risks to raw material quality and safety and are operating effective traceability processes. The approval and monitoring procedure shall be based on one or a combination of:

· supplier audits

· third party audits or certification, e.g. to BRC Global Standards

· supplier questionnaires.

Where approval is based on questionnaires, these shall be reissued at least every three years and suppliers required to notify the site of any significant changes in the interim.

________

Given the above, could a facility working toward BRC certification "grandfather" in all existing approved suppliers, as long as the "new" approval and monitoring procedure meets the intent of the clause and there is some documentation that some of the suppliers have been approved according to the "new" approval and monitoring procedure?

This would be a similar situation to the Training clauses. Company "A" has a bunch of employees that have been doing the same job for 20 years, but do not have a piece of paper to show a "documented" training program. Company "A" states that as of a certain date, all employees currently in positions held are deemed "trained and qualified" in that position. However, after that date, all training will have a paper trail of documentation.

As I read the clause above, the only thing that is required (shall) is that the company has a documented supplier and monitoring procedure. It does not say anything about current suppliers needing to be approved according to that specific procedure.

Comments?

Marshall

[Ames]

I think ideally, it would be best to get all the necessary documentation. I mean, unless your audit is tomorrow or you have 2000 suppliers, is it really THAT difficult to get a questionnaire from each one?

However, if you must grandfather them in, I would personally say do a risk assessment on it. Show that plant history with your current suppliers deems them acceptable and does not pose a risk to safety or quality. Then draw your line in the sand. Beyond that, work towards getting all the necessary documentation for your current suppliers. It shows not only that you're making an effort (rather than trying to find a loophole) but that you truly are committed to quality and food safety. Say you have 20 suppliers grandfathered in. At minimum, get documentation on at least some of them to show you really are trying and be able to prove you've at least contacted the others. I'm with a beef slaughterhouse. We have A LOT (100's!) of cattle suppliers between the sale barns and producers. We still made sure each and everyone of them was sent something to sign. We just couldn't control whether or not we got it back in time.

Personally, if I was auditing, I would hit y'all from the recall standpoint. Sure, your supplier may give you great product, but what if there's a recall? Do you know they have a traceability program? Does it work? Are you really willing to have your name associated with a company that can't give a concrete starting and/or ending point or even know exactly who the affected product was sent to? I may not be a nonconformity (though I'm sure I could find a way), but it sure doesn't look good.

Not sure what you're producing, but could also hit you from the allergen standpoint. You may have a perfect allergen control program. Everything is perfectly labeled, segregated, your labels are checked and double checked and triple checked for accuracy 1000 times a day. However, if they have an undeclared allergen in something they send you because their allergen control program sucks, you're just as screwed. Then tie that back to traceability and guess what...

I think comparing it to the employees is different though. They're in your control. You see them each day you're working. You know what they are or aren't doing. They may try to hide things from you, but it's much harder for them than say a supplier a 1000 miles away. Plus, The Standard requires refresher training for employees. Grandfather employees in or not, they're getting trained within the year based on The Standard like it or not.

[mgourley]

All valid points, but it's not as if we don't have an Approved Supplier Program and "paper" from suppliers that address the points you make.

They are just not nicely wrapped up in one of the three things the BRC Standard mentions.

I have my purchasing department sending out supplier questionnaires after the first of the year to make it all "official".

It will be some time before our BRC audit, so all suppliers should be covered by then.

The whole point of this is I am Risk Assessing and setting up Supplier Approval in a software solution for monitoring our Food Safety System. So I need a baseline approval situation.

A risk assessment based upon past supplier performance and a review of the "paper" that we currently have from each supplier seems like the logical way to achieve that while waiting for the "official" self-assessments to come in.

Thanks
Marshall

[Ames]

From a BRC auditing stand point, you should be fine then. I've prepped for and/or been involved in 6 BRC audits now. It's really a lot more about intent behind things than people realize. Other audits are much more into "we want XYZ so show it to us" rather than BRC that's "show us what you do to meet this concept." I've many times been ok with things because the intent was there as were all the elements even if it wasn't in the nice pretty BRC box.

[Simon]

Just one point on training Marshall. Even if employees have been there 20 years you should at least have a skills / training matrix listing all of the elements relating to the role and ideally supporting that some sort of record signed off by operator and manager. At least then you have established a clear baseline understood and agreed by all (and available to auditors )

Regards,
Simon

[mgourley]

Which we have. Apparently it was not a very good analogy.

Marshall

[Simon]

Something tells me you're going to pass this audit Marshall.

By the way when is it?

Regards,
Simon

[mgourley]

Unscheduled as of yet, but I'm pushing for third quarter.

Marshall

[Simon]

Oh you've got plenty of time...

[mgourley]

Oh you've got plenty of time...

Apparently you do not know my purchasing department. I've been on them for a year to get this done, and now I'm the bad guy.
Whatever.

Marshall

[Simon]

Signing off Marshall, have a great evening buddy.

Regards,
Simon