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Vendor Approval Friday Nightmare - Distributor vs Manufacturer

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fgjuadi

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Posted 14 March 2014 - 07:47 PM

Hi guys!

 

I'm reviewing our current Vendor Approval program.  The way the system was set up, purchasing notifed the QA manager of a new vendor, and the QA manager was in theory getting all of the required documentation.

Hooray, I thought I was all set with vendor approval and only had to worry about new vendors...

 

Then purchasing buys AN INGREDIENT from Amazon.com, and explains to me that amazon is on the approved vendor list, so it should be okay.  A quick look at my ""Approved Vendor List" revealed it is actually a list of distributors.  The "self-assessments" that are on file, which the other QA Manager approved, are covered with N/A and "No HACCP plan".  Which, duh, they're distributors, I expect them to have standards but not to have HACCP plans.  I need supplier assessments for the manufacturer.

 

My purchasing dept is super awesome, but they have no idea who is a distributor and who is a manufacturer, and I think their brains exploded when I told them I need *manufacturer* approval, NOT distributor.  They're upset because their bible list of distributors isn't valid anymore and that I will probably be requireing vendors to have different standards. Also it's a pain in the ass to call up 300 different manufacturers and ask for a vendor self-assessment. 

 

So, my question to all y'all is, in the SQF lvl 3, ISO 9001:2008 and AIB standards (We have ISO, are scheduled for AIB, and want to build to SQF or FSSC 22000),  -  

 

1. I thought I had to get manufacturer approval by auditing their sites/ accepting their 3rd party GFSI standards / getting self assessments & COAs.  When GFSI standards say "Vendor" or "Supplier", they are referring to manufacturer *and* the distributors, right? The whole supply chain?

 

2. Distributors have their own approval step, but this would be much less rigorous and not require GFSI cert docs or HACCP plans or anything crazy.  Mostly a commitment to good GMPs and storage?

 

3. We do not have a lab but I would like to incorporate raw material testing in supplier approval.  Our previous QA Manager belived raw material testing was not necessary because we receive on COA and had letter of guarantee as part of our Vendor Approval program.  Thus, our $$ conserving board has given me a budget of $0.00 for raw material testing.    That's bullshit, right?  The justification is that it is illegal to lie on letters of Guarantee, but ... people do it.  And I want to ensure quality standards of the COA.  Vendor Approval has nothing to do with it?  Or is a good vendor approval program magic that can safely eliminate raw material testing?  Because if I can avoid work, I do, and raw material testing = work.  I want to belive, but it reeks of faulty logic and quality/food safety red flags  to not do any testing.

 

 

Thanks

MM

 

 


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Posted 14 March 2014 - 08:01 PM

Hmmmm, OK  Last minute things on a Friday are a nightmare <been there!> 

 

However, sometimes in our business someone finds an awesome price on cheese. If you can get the ingredient supplier to agree to send you CoAs, a Letter of Guarantee, and the most recent 3rd party audit, that has sufficed for us during SQF level II audits. CoAs should supply some kind of testing relevant to the ingredient.  Moisture, fat and Listeria for cured meats like Pepperoni, Salmonella, E.Coli, etc for eggs, and measurements for size along with pathogen testing for vegetables.  I don't feel receiving companies have the time/resource, etc to do our own Raw Material testing....

 

No one has asked for a distributor's 3rd Party Audit. 

 

GOOD LUCK!


-Setanta         

 

 

 


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Posted 14 March 2014 - 08:04 PM

Hello MM, you need to approve all of your suppliers one step back; including suppliers of raw materials, packaging, transport, storage, pest control, etc.  Within your supply base you need to group suppliers into risk categories and have appropriate approval criteria for each risk category.  I do accept CoA's, but at least once a year I make sure I test one to destruction from each supplier by comparing all elements of the CoA against specification, which could also include testing.  The suppliers know this, but don't know when this unannounced check will be, so it keeps them on their toes and demonstrates proactivity to third party auditors and customer auditors.


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Posted 14 March 2014 - 11:16 PM

 Setanta and Simon had really great advice to get you going in the right direction, so my advice is to remember to breathe!  Deep breaths.........

 

I had to laugh though when you said, "y'all".  I rarely say it but my kids know that when I do, I'm stressed. 


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fgjuadi

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Posted 15 March 2014 - 02:07 PM

Thanks - Annual COA check for high risk first and cutting out distributors to start will be a good baseline to make a robust program.  I like gettign the 3rd party audit instead of asking them to fill out a self assessment, because how the flip am I gonna assess their process, I don't know a thing about it. 

 

I also found this handy forum post which has fun templates to manipulate so I can pretend I'm a designer laying out a poster or something instead of at work - http://www.ifsqn.com...-6-clause-3511/

 

I think I use y'all cuz in Spanish there's "you" and "all of you" words, but in English it's just "you".  But "all y'all"...that means stress.  Just gotta remember nice thigns take time and this is actually awesome because I can make everything right from the start and just like I like it.


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Charles.C

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Posted 15 March 2014 - 11:49 PM

Dear m_m,

 

It just might relate to yr actual products. Or a risk assessment. thereof ? :smile:

 

As i understand, yr primary query is about the control of brokers as suppliers. This is a grey, grey,.... area. 

 

Degree of buyer's control may correlate to the marketing necessity of considering such niceties as brand protection ?. Or frequency of Production emergencies ? :smile:

 

Different FS standards also have noticeable variations in requirements, probably relating to their own drivers, eg due diligence for BRC.

 

I suspect SQF are at the top of the pole  where willingness to trust in (any) piece of paper is involved, a good partner for yr Purchasing Dept perhaps.

 

Rgds / Charles.C


Kind Regards,

 

Charles.C


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Posted 16 March 2014 - 12:30 PM

Does sound like a nightmare MM :yikes:

 

It would be useful to know what products you are manufacturing. I would suggest that you start by categorising suppliers & risk assessing the material/service supplied as this will help you prioritise.

 

Attached File  Supplier RA Categories.png   174.26KB   8 downloads

 

The information you have on file may be adequate for lower risks and categories

 

Regards,

 

Tony



fgjuadi

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Posted 16 March 2014 - 09:56 PM

We manufacture chocolate, and each variety has 4-5 ingredients, for expamle a citrus flavor might have dried lime peel shavings, lemon bits, lemon flavor, lime flavor,  and frozen lemon puree (and of course fancy chocolate).  All from different suppliers, but one or two brokers.    Bob's Yougurt Imporium & Book Shop might sell us butter, evaporated milk, and vanilla paste, and Two Girls and  a Nut Farm might sell us only almonds. 

 

I've stopped the "buying stuff from the supermarket cuz it's cheaper than minimum quantity stuff".( :bye:, Hi, I'm in the QA Department, stop doing that)  I also had to flip my shit at purchasing because they figured out expired ingredients are cheaper and bought something very expensive per lb that I won't let them use.  :angry: 

 

By "supplier", do you mean manufacturer?  What is the definition of is?  :uhm:

 

Last week an operator asked me for the lot number and expiration dates on some macadameia nuts he was going to use and they were in a hand addressed, blank cardboard box.  Inside of that box was a plastic kitchen trash bag :eek_yello: , and the nuts were inside.  Sometimes it seems like a vendor is "some guy in his back yard".  So my goal is to get rid of those vendors.

 

So, I think I'm gonna attack it like this - make a list of ingredients, their risk, who we have as their vendor,  who the manufacturer actually is,  what docs we have from them , and what docs we need.  Then communicate out to manufacturer.  The dealer/broker info we have will be nice, but not needed.  I need the risk assessment to set up raw material testing anyway (anything from a feild is getting metal detected before we use it, wheat & stuff prone to stored product pests will get monthly inspection, annualy COA testing, salmonella and listeria for nuts & melons, powders and liquids sifted, raw chocolate sensory, viscosity, BRIX, and pH testing where appropriate....). 

 

This will erquire a lot of walking around the factory and looking at things.  I'm hoping I cna get most of the info from our Kosher certs, as that program was run excellently and the name on the Kosher Cert will be the name of the *supplier* I want. The dried fruit and dairy we use will be the most difficult.  I'm just glad no one thinks it's a good idea to put meat and shellfish in chocolate.   We have one chocolate type with artificial meat :o , but I hope it doesn't sell, becuase everyone hates making that one. 

 

Thank you for the guidance, some times I think without the message board I would be lost in a sea of "I'm not crazy, right?" food safety doubts.  Sometimes when I ask for things I tihnk are routine QA requests, the staff looks at me like I have three heads.  (O RLY, Pest control guy?  You've *never heard* of writing down a lot number next to the pesticide you're using? Why's it on the form?)


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Tony-C

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Posted 17 March 2014 - 04:34 AM


Edited by Tony-C, 17 March 2014 - 04:35 AM.


Charles.C

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Posted 17 March 2014 - 06:15 AM

Dear m_m,

 

When GFSI standards say "Vendor" or "Supplier", they are referring to manufacturer *and* the distributors, right? The whole supply chain?

 

 

Some confusion seems existing.

 

i assume you are the manufacturer.(?)

 

Just to expand Tony's definition -

Supplier typically relates to whoever has made an agreed product delivery quality/safety specification (APS)  with yourself, ie is responsible for the product. This usually  goes one step back into what may sometimes be a complex chain. Similar to traceability.

 

In many Companies it is simply the 2 sides of a Purchase Contract based on a Purchase Specification.

 

I think you can guess who the vendor is.

 

There are 2 basic contributions to Supplier approval IMEX – (a) initial and (b)on-going. You are currently discussing (a), I think.

 

IMEX, the APS has been the QA/Company’s minimum requirement for a purchase of the lowest risk class items.

 

This  base supports a structure due RA factors such as Tony mentions, eg via certifications, audits, questionnaires, etc .

 

From memory BRC Food has a quite comprehensive summary of this topic/requirements. Try comparing to SQF.

 

Rgds / Charles.C

 

 

PS - added - i do agree that confusion is not difficult to achieve :smile: , eg -

 

http://en.wikipedia.org/wiki/Vendor


Kind Regards,

 

Charles.C


fgjuadi

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Posted 20 March 2014 - 11:44 AM

Update - Thanks for your help! I ended up with this guy to start with.  I'm sure it will grow as I do :)

 

http://www.ifsqn.com...l-matrix-draft/


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Posted 23 March 2014 - 03:28 AM

Dear magenta_m

 

Thks for the draft excel. i appreciate that this is tailored to yr own requirements however i thought a few  general/random observations might be useful based on other formats I hv seen.

 

(1) “Ingredient” heading is OK but typically not a general word for Inputs, eg combined with raw material/packaging. But perhaps you have parallel  forms ?

(2) Several columns are really part of the product specification which you (rightly) emphasise first.

(3) A GFSI audit does not exist anywhere but perhaps this is now typical American usage/slang  (like HACCP standard)?

(4) No mention of “Supplier”. American format perhaps but not, i think, typical International. Some ingredients for some processors have no “manufacturer”, eg fish. but they always have a nominal “Supplier” (EQV traceability).

(5) Supplier’s own “credentials”, eg certifications. ISO etc

(6) Risk status of input items (would be linked to control).

(7) Current status, eg including ongoing control.

 

(NB, EQV=equivalent, sad that no keyboards afaik have the math.symbol)

 

Rgds / Charles.C


Kind Regards,

 

Charles.C


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fgjuadi

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Posted 24 March 2014 - 10:00 AM

Thank you, these are helpful. Ingredient should be raw material and manufacturer should be supplier.  I'll spilt it into "raw material testing" once I have it populated.  Seemed easier to put it all in  one while I'm contacting everyone for SDS, specs etc. GFSI audit means "I have a cert on file for BRC/SQF/FSC22000/CandaGAP etc."  


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ChocolatesMyGame

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Posted 18 June 2014 - 07:43 PM

I feel like we work at sister companies!  I am also at a chocolate and nut facility and working towards SQF. I literally just had this same conversation with our purchasing manager- he wanted to give me broker information and I had to convince him they are not a manufacturer and therefore don't have a spec for the product!  I feel your pain...  

 

What I did to track everything was create a spreadsheet with 3 tabs as outlined below:

 

1. Name of vendor, brief description of vendor, date we received the supplier assessment,  what lever of certification (if any) they have, and frequency of audit/assessment.

2.  List of all ingredients with the vendor name(s), date spec was received, and date kosher cert was received (also used as the Approved Supplier List).

3.  Log of supplier complaints to guide us on if we need to be auditing or reviewing any of the suppliers more frequently than designated.

 

I've told purchasing this will be THE BIBLE of what they can order from unless they approve someone else through me first in emergency situations.  So far seems to be working well...



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fgjuadi

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Posted 18 June 2014 - 08:44 PM

I feel like we work at sister companies!

:off_topic:

 

I literally think this any time someone on here posts about chocolate.  Moving past how cool it would be to know someone from the interentz in real life, how cool would it be if we both used the same forum!   You seem too well adjusted to be part of my sister company, and their purchasing dept is one lady (sorry, I'm not your other QA, but keep looking!).

 

It's kind of like a game of Clue where I'm checking off different IFSQN members based on random factory observations that don't gel-  "Oh, you have a male purchasing manger, guess she's not "Chocolatesmygame". "Oh, that person lives where it's snowing right now, guess she's not my sister from another motha"  "Oh, that person has the ability to form logical conclusions,  and humility to accept they made an error, guess I'll keep looking"  I should probably grow some balls and ask her what website she uses and what her handle is, but I don't want to give away mine :ninja: ! I'm not proud, but I get frustrated with her a lot becuase we have very different styles. And this is my escape where I can  voice those frustrations.

 

I didnt' realize how many tiny chocolate manufacturers there were until I went to my SQF prep course - out of 30 students, there were 4 different chocolate companies!  We should all buy the same ingredients & divy  up  the vendor approval tasks amoungst us.

 

I feel like we work at sister companies!  I am also at a chocolate and nut facility and working towards SQF. I literally just had this same conversation with our purchasing manager- he wanted to give me broker information and I had to convince him they are not a manufacturer and therefore don't have a spec for the product!  I feel your pain...  

 

What I did to track everything was create a spreadsheet with 3 tabs as outlined below:

 

1. Name of vendor, brief description of vendor, date we received the supplier assessment,  what lever of certification (if any) they have, and frequency of audit/assessment.

2.  List of all ingredients with the vendor name(s), date spec was received, and date kosher cert was received (also used as the Approved Supplier List).

3.  Log of supplier complaints to guide us on if we need to be auditing or reviewing any of the suppliers more frequently than designated.

 

I've told purchasing this will be THE BIBLE of what they can order from unless they approve someone else through me first in emergency situations.  So far seems to be working well...

Ah, I'm using the file I uploaded here, it basically has all of that crammed into one sheet...not the prettiest design wise but functional.  Purchasing can't handle the concept of a list of vendors right now.

 

Purchasing has basically decided "flip it" when it comes to anything QA  because I'm constantly putting stuff on hold for no COA and our board is constantly over riding the hold  to use ingredients in production.  S I threaten that we need to get documents like this or face a hold, but it's not like upper managemnet would allow a late or incomplete order, so  no chance they're going to do it. They just wait until the wire and then drop the "US Foods doesn't give product specs for that item" / "I ordered twenty pallets from ebay.com, okay?" out there and the management approves it for use "this one time". I'm so over you, purchasing department.  If there was a website for purchasing departments, I would go flame them now.

 

http://www.ifsqn.com...-provide-a-coa/


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zawape

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Posted 02 May 2018 - 01:11 PM

"The justification is that it is illegal to lie on letters of Guarantee" would you or someone please elaborate on this? I am not aware of any federal or state law that indicates that. I am located in the US. Thank you in advance.


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Posted 02 May 2018 - 01:44 PM

a letter of guarantee is a binding document. That's why you'll usually find a statement something like "at the time of testing"  or "as per our lab results" or some such legal release. They can only guarantee based on the information they have given and usually include the date it was issued and the date at which it is no longer valid. If you do not store say a refrigerated raw material in a cooler, then swab it yourself and get off the charts TPC you cannot go back to the LOG and claim it was false. But companies have been known to lie, say item X was produced in a facility that is nut free in order to get more business when in fact they have 1 item in the facility that contains say walnuts that sort of thing

 

Depending on what your raw inputs are an LOG may not be enough, you may also want a certificate of analysis for each lot that you purchase.

 

I myself get 3rd party audit certificates, C of A and the general food safety statement including allergen management from all of my suppliers. If you're dealing with companies that work above board and are transparent, this will not be a difficult list of documents to obtain

 

My general statement for what we all do for a living "we are lawyers who did not go to law school"   It is our job NOT to take anyone at face value and ensure we produce SAFE WHOLESOME FOOD, even when that means doing the hard jobs...........like not releasing product or not allowing the use of 20 pallets of product bought on ebay (sorry you wasted your money......should have talked to me first)


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Posted 02 May 2018 - 01:46 PM

 Guarantees and warranties are legally binding on the business – they are enforceable through the courts if necessary. And remember also that you still have your consumer rights if something goes wrong, regardless of any guarantee or warranty. 

 

 

 

Section 303 of the Federal Food, Drug, and Cosmetic Act

Section 303 of the Federal Food, Drug, and Cosmetic Act (the Act) provides penalties for persons who violate certain provisions of the Act. Section 303, paragraph © of the Act states that no person shall be subject to the penalties of subsection (a)(1) for having received, or proffered delivery of, adulterated or misbranded food additives if he has established a good faith guarantee from whom he received the articles. This paragraph was included in the 1958 amendments to the Federal Food, Drug and Cosmetic Act and remains the legal basis for the "letter of guaranty" supplied by many manufacturers to their clients. Title 21 CFR 7.12 Guaranty and Title 21 CFR 7.13Suggested forms of guaranty, provide example language for such a letter of guarantee.


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