6 replies to this topic

[zay]

I'm in need of a little bit of guidance based on others experience!

 

I'm a third party packing and storage facility and as such I have no ownership over any of the raw material we handle ~ and I'm struggling with Section 3.5.1.2 ~ it say I shall have a documented supplier approval for all raw materials. Not sure how I can do this when I don't do any of the buying?? 

 

and the vulnerability assessment 5.4.2!

 

 

Any suggestions would be appreciated

 

Tried asking my certication body but they are not getting back to me on this one.

 

Do I just need to put a disclaimer in my QM stating the obvious and that will tick that box??

 

Any advice will be greatly appreciated

[Simon]

It may be possible that you can have an exclusion over supplier approval on raw materials...exclusions need to be documented in your manual to say what you want to exclude and why.  Exclusions need to be agreed with your certification body.  You will still need some supplier approval for other suppliers such as pest control and probably others you use.

 

As for vulnerability assessment of the raw materials then that is your customers responsibility so again could be an exclusion.  You would likely be mentioned in your customers vulnerability assessments as a step that needs control.  As such you need to have very tight security controls for the site, employees, visitors, vehicles etc. to support them.

 

I'm no expert, but I hope this helps a bit.

 

Regards,

Simon

[zay]

Thank you ~ Ill keep this one in mind.

 

I'll let you know how I get on when I'm audited.

[IzzyP]

I'm in a similar position to you, in that everything we receive is approved and supplied by our customer. We call this Free Issue.

 

Unfortunately, it doesn't mean that you can just ignore this clause. You will still need to demonstrate that you have some sort of "Supplier Approval" system. my understanding is , that It would not be sufficient to say that items are free issue, and that you take no responsibility. The same goes for the vulnerability clauses.

 

It doesn't have to be elaborate. A simple spreadsheet suffices. List all of you Suppliers (Customers) and then list their suppliers along side. I appreciate that this step might not be so easy as customers can be secretive, Ask you supplier to forward copies of BRC / GFSI/ISO certificates (and reports if you can get them). Check the scope of these reports (are they covered for the product they supply into you). Check that they are valid against the BRC Directory and have not been withdrawn. You can add as many columns to your spreadsheet as you see fit for your business. I have about 30 or so columns in mine. But the one thing you can't do, is nothing.

[zay]

Thanks ~ I was thinking along the same lines, just wasn't sure how far to take it.

 

This gives me a starting point ~:)

[Charles.C]

Hi zay,

 

Possibly slightly OT (scope unknown) but there is a a long (probably BRC) thread over the processor"s responsibility for retail product safety in UK in a situation as you describe with respect to labelling.

.

Appears the processor may share the liability for any subsequent events in case of ignoring an evident "defect" albeit not possessing ownership.

 

Just a caveat.

 

The suggested protection was  liability insurance.

[DavidAR]

Interesting, but i think your all forgetting one important bit of information that is missing here.

 

He is a 3rd party storage and packing fascility, but does not mention what, if any type of certificated system they have incorporated in to their buisiness.

 

i agree with all comments but not enough information on HIS system as it stands to really use any reference. comments made assume certain systems in place already. no?