Raw Material Risk Assessment as it relates to GFSI
Hi All!
First off, great forum; I've really enjoyed lurking here & there!
Quick background on us. . we're a smallish custom dry blend plant (SQF 2) with literally hundreds of ingredients.
When it comes to Raw Material Risk Assessment. .
We're getting more & more pushback upon documentation requests (HACCP flow charts, etc) from suppliers esentially saying you have our GFSI certificate, what more do you need?
I guess my question is: is a GFSI cert enough to let the ingredient 'pass go' so to speak?
Here I sit trying to piece together the HACCP program of these suppliers on my little computer in my corner of the world. . how can my assessment compare to a GFSI auditor's asssessment on-site?
Can ingredients be added to our HACCP register & thus purchased & used based on the merit of their cert?
I do hope that all made sense.
I'd appreciate anyone's opinion--thanks much!
Joan
Hi Joan,
our approach is as follows.
4.3.1 A risk assessment is undertaken with regards to GFSI bench-marked or a combination of ISO 9001/GMP and ISO 22000/HACCP certification, satisfactory completion of the SAQ & COS, product food safety risk, importance and country of origin. As a rule of thumb, any suppplier not suitably certified, or who is but has submitted an unsatisfactorily completed SAQ (and supporting docs) will trigger an audit:
The potential supplier is given a score:
1) Low Risk
2) Medium Risk
3) High Risk
4.3.2 Following action determined:
Risk Level 1) SAQ and COS issued, current 3rd Party accredited certification obtained.
Risk Level 2) SAQ and COS issued, current 3rd Party accredited certification, HACCP documents and supporting information obtained.
Risk Level 3) SAQ and COS issued, current 3rd Party Accredited certification, HACCP documents and supporting information obtained and Direct Supplier Audit by a suitably experienced auditor considered.
4.3.3 Any required corrective actions are completed with appropriate documentation and/or timescales agreed.
We have about 100 suppliers and my boss spends about half his time auditing them, I spend about half my time keeping up to date with them.
We keep:
GFSI and other certificates and the audit reports as well as our SAQ
HACCP plan
Specs
CofA and authenticity
Copies of relevant policies
Contract details
Possibly over the top, but most are happy to conform.
Hope this helps.
Jim
Hi Brummy jim,
2 new ones to me -
SAQ = ?
COS = ?
Supplier Assessment Questionnaire
Conditions of Supply
Jim
Supplier Assessment Questionnaire
Conditions of Supply
Jim
thanks for above / yr input. I guess that COS is a term of convenience.
And one more - CofA ?
I anticipate that the basic (minimal) answer to jawiese's OP/Qu.1 is that "it depends on the text/Guidance of the SQF Standard".
Is that satisfied by a "satisfactory" SAQ and/or a "satisfactory" 3rd party audit from a GFSI benchmarked CB ? (I'm guessing that COS is internal only)
And my sympathies to the time involved. i feel yr pain.
Certificate of Analysis - for each purchase
The Conditions of Supply is effectively the contract. All these are renewed each year (for services as well including transport - 30 transport/warehousing suppliers!).
It's quite a challenge, but our suppliers are around the globe, so we have little choice. New Zealand to South America via Europe (and considering Africa).
Jim
Certificate of Analysis - for each purchase
The Conditions of Supply is effectively the contract. All these are renewed each year (for services as well including transport - 30 transport/warehousing suppliers!).
It's quite a challenge, but our suppliers are around the globe, so we have little choice. New Zealand to South America via Europe (and considering Africa).
Jim
Ahh yes COA of course.
The solution to the OP appears to be Implementation/Auditing Guidance 2.4.5, pg 33. Assuming it’s current.
I am an auditor who spends time auditing drinks suppliers in UK, europe and other parts of the world. The reason for some companies not trusting the GFSI certification is the different interpretation of the standards such as BRC. I am sure that a BRC grade A in the UK is significantly different than other parts of the world. I am aware that an audit is a snapshot in time but the trends is a looser interpretation of the standard. Ideally the standard of auditing would have the same level of rigour across all countries and standards and they would be trusted more
Risk Assessment is different than Supplier Approval but they are linked. Risk assessment would be done for the raw materials despite who your supplier might be. Also, the risk of contaminated materials coming from suppliers is different than the risks for storing or cross-comtamination (such as allergens) of raw materials at your site.
Supplier approval is based on the assigned risk level per BrummyJim's explanation above. The higher the risk, the more you require from your supplier. This should be described in your procedure for approving suppliers.
Supplier approval also needs to have an annual review. Once approved doesn't necessarily mean always approved. Your supplier approval procedure should describe how you review and renew approval for suppliers.
Approved types of raw materials (such as spices) doesn't mean that a supplier is approved.
Approval of a supplier doesn't mean all their products are approved (such as peanuts as a food allergen).
You thus have a three activities:
1. The risks of the raw materials and their control plans at your location and the control plans you would require of any and all suppliers.
2. Supplier approval based on the risk level of the raw materials and what evidence you require from the supplier based on the raw material risk level.
3. Review and approval of individual raw materials from an approved supplier, or your testing plan to approve materials from an unapproved supplier.
I guess we are a little different. From our position, a product from Thailand is not the same as if it came from a Mexican producer. Effectively each supplier produces a unique product even if it has the same name (e.g. Pineapple Juice). Thus we can assess the risk from the manufacturers as if it is a raw material risk assessment. Be aware that commodity is not necessarily commodity!
Thanks everyone for your responses & discussion!
Thank you Heywood for making the distinction. . Risk Assessment vs. Supplier Approval.
My question relates to HACCP Risk Assessment.
Is a GFSI certification enough justification for passing an ingredient thru your HACCP Risk Assessment??