31 replies to this topic

[Koko LMQ]

Quoted:

 

The company shall have a documented supplier approval and ongoing monitoring procedure ................... The approval and monitoring

 

procedure shall be based on risk and include one or a combination of:

 

• certification (e.g. to BRC Global Standards or other GFSI-recognised scheme)

 

• supplier audits, with a scope to include product safety, traceability, HACCP review and good manufacturing practices, undertaken by an experienced and demonstrably competent product safety auditor

 

or, for suppliers assessed as low risk only, supplier questionnaires."

 

2 BRC ATP trainers confirmed that BRC required if the company chooses the certifications, all certifications shall be ONLY BRC or GFSI recognized schemes, not allowed to other, e.g. ISO 22000, HACCP or GAP while the standard uses "e.g.".

 

I have 100 ingredients suppliers at overseas, can them all certified to GFSI schemes? I have 500 vegetable growers with local GAP, can them all certified to GLOBALG.A.P?

 

if I have to go to do suppliers what a huge cost is.

 

What do you think?

[DRL]

Hi naronchai_y The way I understand it is that the standards if benchmarked and recognised by GFSI then if you or your suppliers implement one of the recognized standards then you should meet the requirement. Maybe there are some regional issues in your area with having available providers of audits or training. As far as supplier approval I would think that basing your decision to get product from a supplier that either you ensure they: 1. have a GFSI recognised certification, or 2. send them a questionnaire, request that they supply COA's for product from an accredited lab and you test the product (you randomly sample and use as a decision making tool to continue using them or discontinue using them as a supplier), or 3. audit them and assess their level of control of risks, request COA's and also test product as in #2

Hope this helps. Daryl

 

 

 

 think there are more options for you. You can set up a supplier monitoring program which would involve setting up specs for the products / ingredients. Then test the inomingis a third option

[Koko LMQ]

DRL

 

I just would like to focus on the "Certification". For other methods are OK if sites choose those. But why BRC limited the certification only to BRC or GFSI recognized schemes.

 

NY

[Koko LMQ]

Just update

 

Now BRC announced to all that other food safety management system certifications are accepted but the certified sites shall request supplier to send their audit reports and also the auditor's profile.

[Tony-C]

Just update

 

Now BRC announced to all that other food safety management system certifications are accepted but the certified sites shall request supplier to send their audit reports and also the auditor's profile.

 

Hi Koko

 

BRC Global Standard for Food Safety Issue 7 January 2015:
Clause 3.5.1.2
The approval and monitoring procedure shall be based on risk and include one or a combination of:
• certiication (e.g. to BRC Global Standards or other GFSI-recognised scheme)

 

Regards,

 

Tony
 

[Charles.C]

Hi Koko,

 

With respect to the quote in previous post, can you provide a reference/link to support yr statement in post 4 ?

[Koko LMQ]

Hi Charles C.

 

Unfortunately, I cannot give the link as it is stated in the "Webinar - Auditor Calibration" which posted at "BRC Participate". If you subscribe to that, you can see it.

 

KoKo

[Charles.C]

Hi Koko,

 

Thanks for reply.

 

TBH, I'm not sure if  that source  is definitive or not. And personally no way to look.

 

I would have thought BRC would have to announce it publicly if it was a major revision of the Standard (which it would be IMO). Like in their monthly newsletter.

[Charles.C]

Addendum to previous.

 

Hi Koko,

 

Yr info. looks "related" to the document linked in post below. The latter's content/deductions  to me seemed (so far) inconclusive (ie officially unconfirmed).

 

http://www.ifsqn.com...511/#entry97246

[Koko LMQ]

Hi Charles,

 

Yes, it is the same conclusion from BRC Technical Director as your linked discussion. However, I also do not yet see the formal announcement from BRC publicly on this matter. In the first issue of BRC Food Issue 7, all approved trainers insist that only the GFSI certificated is acceptable, not for non-GFSI. I think there are a lot feedback to BRC and then the Director hold the webinar and calibrate their BRC auditors by acceptance of non-GFSI with bellowed conditions.

 

"A third party audit may be acceptable as an alternative to completing your own site audit where all the following criteria are satisfied:

• the scope of the 3rd party audit covers all the items listed in the clause for supplier audits e.g. HACCP review, product safety, traceability, etc.
• the competency and training of the auditor is known
• you have access to a copy of the full audit report (a copy of the certificate alone is not considered sufficient)”

 

Koko

[Charles.C]

Hi Koko,

This previous related forum thread (Oct 2015) contains both possible (GFSI-involved) interpretations  (see Posts 2,3). But I get the impression that both are speculative rather than based on audit experience.

http://www.ifsqn.com...plier-approval/

These 2 (non-BRC) links (undated/Oct.2015) support yr current understanding -

http://www.salsafood...etail.php?n=354

http://www.tracegain...on-conformities

Strictly IMO "one or a combination" supports yr interpretation but with BRC..........

When was the webinar you mention released ?

It appears BRC have avoided official clarification of this known uncertainty. Because the solution looks too "easy" ?

 

Maybe the Guidelines clarify further ?

[Tony-C]

"A third party audit may be acceptable as an alternative to completing your own site audit where all the following criteria are satisfied:

 

BRC Interpretation Guideline states:

Approval must be based on a risk assessment of the supplier and could therefore include a range of activities, such as the following:
• A third-party certification scheme incorporating product safety, such as the Global Standards for food, packaging, storage and distribution, or agents and brokers.

[Charles.C]

BRC Interpretation Guideline states:

Approval must be based on a risk assessment of the supplier and could therefore include a range of activities, such as the following:
• A third-party certification scheme incorporating product safety, such as the Global Standards for food, packaging, storage and distribution, or agents and brokers.

 

Hi Tony,

 

Thanks. The Guideline seems quite "general".

 

So the conclusion is that supplier approval in BRC7 only differs from  BRC6 regarding (a) the utility of questionnaires (low risk material only) and (b) the injection of "GFSI recognized" to a supplier's being certified.

 

Looks like good business for (competent) survey companies.

 

PS  + the fraud elements of course.

Edited by Charles.C, 29 January 2016 - 08:17 PM.
expanded slightly

[Charles.C]

addendum - to answer my own comment -  this looks like a more precise summary - (3,4,9) look additionally notable points. (5) is nicely subjective.

 

1. Your raw material risk assessment must now be reviewed annually. (Clause 3.5.1.1)
2. The raw material risk assessment must now include substitution or fraud of ingredients (this section covers packaging but substitution or fraud need only cover ingredients), but the vulnerability assessment conducted in section 5.4 can be used to cover this requirement. I’m not really sure why they didn’t include the requirements of 5.4 in this section, it makes it confusing splitting them up. (Clause 3.5.1.1)
3. Supplier approval and monitoring must now include food contact packaging, but also consumer packaging – which means any packaging that the consumer receives with the products (even if it’s not food contact). (Clause 3.5.1.2)
4. The scope of supplier audits has now been defined to include as a minimum HACCP, traceability, product safety and GMP. (Clause 3.5.1.2).
5. Supplier audits must also be carried out by an experienced and demonstrably competent auditor. This means that the auditor doesn’t need to be qualified but must be able to demonstrate that they know how to complete an audit to a good standard. (Clause 3.5.1.2)
6. Supplier questionnaires can no longer be used for any suppliers, other than those that are defined by the supplier risk assessment as low risk. (Clause 3.5.1.2)
7. You also now need to have an up to date list of approved suppliers. (Clause 3.5.1.2)
8. When using agents and brokers, all approval and monitoring criteria must be applied to the last manufacturer or packer of the material, to assess just the agent/broker is not sufficient. Unless, the agent or broker holds a BRC Agents & Brokers certificate – if they do, to assess just the agent/broker is acceptable. (Clause 3.5.1.3)
9. Where raw materials have been used without following the approval process (these are known as exceptions), these exceptions must be made known to your affected customers – implying that they would need to approve. (Clause 3.5.1.4)

[Koko LMQ]

Hi Charles,
 
The webinar held before May 2015 but the material is posted in August. I try to capture only that issue.

 

 
KoKo

[Koko LMQ]

 Food Auditor Calibration 5.docx   565.74KB   553 downloadsHi Charles,

 

Here it is.

 

Koko

[sannatone]

I'm struggling trying to come up with some simple criteria to determine low risk and non low risk for our suppliers.

I see that it is ultimately up to the company to come up with a definition or calculation.

I'm just thinking there should be some standard set of criteria.

 

We have  a set of criteria in place for raw material risk assessment.

For this - we were thinking of past complaint history and historical performance.

 

Does anyone have a simple definition or set of criteria they use to rate their suppliers as low risk/non-low risk?

 

thanks - Susan

 

[Kehlan]

Susan, when we did ours, we looked at a set of questions, including how long we have had a relationship with the supplier, do they have pesticide test results, what type of supplier they are (ie direct supplier, cooperative, agent etc), are they traceable to the field etc.  For each question we scored them from 1 to 4 where 1 might be we have worked with them for years and 4 might be they are a completely new supplier, for pesticides 1 might be that they have several years results all of which have no chemicals found and 4 might be they have had exceedances and so on.... then we added up the scores and set a limit that we considered reasonable for low risk, medium risk and high risk.  The BRC auditor liked the system and it worked well for us.. obviously your questions would change depending on the products in question but it give you an idea.  Hope it helps.

[Anika]

I'm struggling trying to come up with some simple criteria to determine low risk and non low risk for our suppliers.

I see that it is ultimately up to the company to come up with a definition or calculation.

I'm just thinking there should be some standard set of criteria.

 

We have  a set of criteria in place for raw material risk assessment.

For this - we were thinking of past complaint history and historical performance.

 

Does anyone have a simple definition or set of criteria they use to rate their suppliers as low risk/non-low risk?

 

thanks - Susan

Agree with what Kehlan posted. Our RA is based on three criteria: Significance to Quality + HACCP(physical, chemical, biological) +VACCP

Attached Files

•  Capture.PNG   255.45KB   12 downloads

[Charles.C]

Agree with what Kehlan posted. Our RA is based on three criteria: Significance to Quality + HACCP(physical, chemical, biological) +VACCP

 

Hi Anika,

 

Thks for input/pic. Very nice.

 

Looks like a developed version of the excel (BRC6) attached in post below with some updating to BRC7, ie including  the VA reqs -

 

http://www.ifsqn.com...511/#entry52714

[dido_]

Dear Charles,

We are a spice manufacturer(BRC certified) and our supply chain may be very long for some items, thinking all of raw materials are agricultural materials. So, I have took your system and created a raw material risk assessment including vulnerability and got a raw material score for each item. Even though, I have reviewed the examples you have referred to, I still have confusion to integrate raw material assessment score to overall supplier risk score. I think that raw material risk score should be important and effect supplier risk score(which will determine the type of approval). As BRC states, in case of any emerging or increasing issue for some items, maybe it should differ the supplier score, too. Can you please clarify the approval and frequency determination method in your example? Do you think the raw material risk score should effect supplier score?(low risk/medium risk/high risk)

Hope, its been clear.

Thanks,

Dido

[Charles.C]

Dear Charles,

We are a spice manufacturer(BRC certified) and our supply chain may be very long for some items, thinking all of raw materials are agricultural materials. So, I have took your system and created a raw material risk assessment including vulnerability and got a raw material score for each item. Even though, I have reviewed the examples you have referred to, I still have confusion to integrate raw material assessment score to overall supplier risk score. I think that raw material risk score should be important and effect supplier risk score(which will determine the type of approval). As BRC states, in case of any emerging or increasing issue for some items, maybe it should differ the supplier score, too. Can you please clarify the approval and frequency determination method in your example? Do you think the raw material risk score should effect supplier score?(low risk/medium risk/high risk)

Hope, its been clear.

Thanks,

Dido

 

Hi Dido,

 

The combination of  (a) (specific) raw material risk and (b) (specific) supplier's own "internal" risk in respect to an overall supplier risk is discussed here (and elsewhere) -

 

https://www.ifsqn.co...ng/#entry128133

 

https://www.ifsqn.co...al/#entry136778

(also see posts before and after above in both threads)

 

afaik,  BRC have simply avoided elaboration on this aspect in their Interpretation Guidelines.

 

Offhand I don't recall any feedback here indicating that BRC require a specific solution, ie they are flexible as long as the final result looks plausible.

 

PS - Feedback from other BRC users welcome of course !

[QM-OS]

In the first 5 or so years of our BRC work we didn't have the product risk assessment in consideration when evaluating suppliers.

None of the auditors during these years found this to be a non-compliance. 

 

 

Awhile ago we changed our routine for evaluating suppliers. We now take the product risk and combine it with overall supplier risk and that generates a final risk "grade".

If a supplier deliver different products with different risk levels we consider the higher risk when generating the final grade.

So far, none of the auditors have had any problems with this way, either...

[Charles.C]

In the first 5 or so years of our BRC work we didn't have the product risk assessment in consideration when evaluating suppliers.

None of the auditors during these years found this to be a non-compliance. 

 

 

Awhile ago we changed our routine for evaluating suppliers. We now take the product risk and combine it with overall supplier risk and that generates a final risk "grade".

If a supplier deliver different products with different risk levels we consider the higher risk when generating the final grade.

So far, none of the auditors have had any problems with this way, either...

Hi QM-OS,

 

Thks for input.

 

IIRC, the BRC Code contains no specific requirement to generate a Supplier Grading per se although BRC do refer to a "Low Risk" Supplier, This Supplier classifier is conspicuously absent in the Glossary list of definitions/interpretations. (And similarly for "Low Risk product".)

 

^^^^(red) I assume you mean that no critical comments were received. Truly astonishing IMO. It's always been my first query where external audits are concerned.

 

One might consider that, just as production zones have (specifically) different expectations for low/high risk area scenarios, this should also be relevant to a Supplier's Grading. Might be especially relevant for example where a "nominal" low risk product will be further processed downstream.

 

I daresay BRC choose to stay away from such conundrums and are happy that you chose the most.overtly conservative option.

[mgourley]

IMO, "Supplier Risk" should be included if you are risk assessing a material from the supplier.

If you have a high risk supplier, (why are you buying from them in the first place  ), that should certainly play a part in the risk assessment of the material.

 

Marshall