Supplier Approval 3.5.1.3

Hi

If we buy a range of ingredients from a supplier that they manufacture and 1 ingredient is bought in by that supplier, does that make them a supplier and a broker?

If so, if they have BRC for Food Safety rather than for BRC for Agents and Brokers, would that be sufficient?

The clause states that if you purchase ingredients from a agent or broker you must obtain information to approve the manufacturing site unless the agent/broker has BRC for agent/brokers. But what if they have BRC for food safety instead because they actually manufacture themselves as well as acting as a broker for certain products? Would they need both?

Thanks

Any help is much appreciated.

W

Hi,

I would say you need to approve the manufacturing site too through supplier approval and/or third party verification depending on your risk assessment unless they have BRC for agents and Brokers as well as BRC FS.

The goal would be to trace back ingredients to manufacturing site or farm(in case of fruits and vegetables)

Thanks

Thanks for your response, the product is food colour. We buy in 8 different ones from the same supplier, 5 they make and 3 they buy in.

I don't know the standard for agents and brokers but I was thinking that surely the same supplier approval should apply for agents and brokers as it does for food manufacturers? therefore would just having BRC FS not suffice?

thanks

Hi Whitney,

We are both manufacturers (we repack and blend juices) and brokers (and agents as well, just for fun). We decided a while back that we needed to have both standards. It wasn't particularly difficult as the standards only diverge slightly.

You will need a separate HACCP/VACCP/TACCP though which we did find a little challenging. We ended up with a larger document than for manufacturing, with no CCPs. The auditor still found fault with it!

Hi Whitney,

Perhaps i have misunderstood the situation  but I'm confused. :smile:

If you are "A", your supplier is "B" (certified to BRC7) and "B"'s supplier is "C" then -

Surely the scope of B's certification to BRC7 must include any items having been bought in from C so that any such items must  already have been "covered" from BRC's POV ?

afaik, BRC traceability requirements only necessitate identification of the path 1 stage  both ways from the designated "auditee" ?

Charles,

BRC7 would only cover the manufacturing side of the business, not the agent/broker/wholesaler side unless specifically included. The Agents & Brokers standard covers the latter.

Hi Jim,

Yes, i get yr point.

I'm simply challenging BRC's logic if you are correct..

Thanks for your comments

Yes Charles that is what I am thinking also. If supplier B is BRC FS accredited then would they need BRC for agents and brokers as well? Surely they would be covered with just BRC FS....

Hi Jim

what do you mean I will need a separate HACCP? I am confused. We are a manufacturer that buy in ingredients to produce our product. its the supplier of the food colours we buy that not only produce the colours, they buy some in and repack them. We take both kinds from them. The ones they manufacture and the ones they buy in.

The supplier themselves have BRC v7 FS, are you saying that they would also need BRC for agents and brokers?

thanks

Sorry, my mistake. They need a HACCP for Agents & Brokers. You might find it interesting to read.

I am in a similar situation, where we purchase ingredients from a supplier who acts as an agent/broker/distributor.  I can't imagine how my supplier could provide me with the information about the manufacturer of the ingredient.  It is very convoluted. 

I understand 3.5.1.3 to say that if my supplier is an agent/broker, that they must provide me with the details of the manufacturer of the ingredient, unless they have BRC for agents/brokers.  What a GREAT way for BRC to make more money by making it ridiculous for us to be able to truly approve every ingredient provided to us.

What about examples where I purchase an ingredient from company "A", who purchases it from company "B", who purchases it from company "C"???

My ingredient supplier questionnaire is 8 pages long.  How on earth is my supplier supposed to complete it based on the manufacturer of the actual product, when it goes through several brokers and distributors just to get there?  

Hi PWIC,

I guess the fundamental point  from BRC's POV is that a person/company selling such products  must be responsible for their food safety/Quality, (and must be able to document such acceptability). 

The classic case IMEX is where Production/ Purchasing simply go out and buy flavours / colours of Brand XYZ from a supermarket.

My ingredient supplier questionnaire is 8 pages long.  How on earth is my supplier supposed to complete it based on the manufacturer of the actual product, when it goes through several brokers and distributors just to get there?

Traceability zero ?  It might be argued that the biggest mistake lays with the Purchasing Section / Purchasing Policy ?

In current thread, I would have opined that "A's"  Purchasing section should have obtained appropriate documentation from "B" (the latter IMO should have already had it "on tap" as per their own Certification to BRC, eg within the Product specification)( I am assuming Food Grade ingredients are involved).

Hi,

I would suggest that supplier to certify BRC Food and AVM Traded Goods.

KoKo LMQ

Hi,

 

I would suggest that supplier to certify BRC Food and AVM Traded Goods.

 

KoKo LMQ

Hi Koko,

Sorry but i don't understand yr comment.

"that supplier" - which supplier ?

 AVM - what is AVM ?

BRC now allows the site to certify BRC Food and additional voluntary module (AVM). Your supplier is manufacturer and also the broker trading goods so this AVM Traded Goods is applicable.

BRC now allows the site to certify BRC Food and additional voluntary module (AVM). Your supplier is manufacturer and also the broker trading goods so this AVM Traded Goods is applicable.

Hi Koko,

Thks for yr patience.

I deduce you are referring to this -

The voluntary modules published alongside the BRC Global Standard for Food Safety Issue 7 have been designed to reduce multiple audits by covering additional specific geographical or customer requirements and auditing them at the same time as the BRC audit.

This module is applicable to food products that would normally fall within the scope of the BRC Global Standard for Food Safety Issue 7 but which are not manufactured, further processed or repacked into primary packaging at the site being audited.

The scope of this module covers products that meet all of the following criteria:

• be purchased (take title to) and sold by the company
• be received into storage facilities at the site
• all the storage facilities used for the product shall be included within the scope of the Standard.

 

After reading the above module (8) it's convolution in the current context defeated my understanding.

As stated I find the above quoted terms "sold",  "food product", "(not??) further processed"  ambiguous.

Offhand i would consider any inputted raw materials/ingredients for manufacturer "A" as becoming  "further processed"  thereby possibly (see above ??) rendering module 8 irrelevant for present purposes. But frankly, i was unable to decide if relevant or irrelevant.

It seems to me the logical crux of the issue is as per post 12 but no problem to be refuted.

Either way, thanks for the input.

Hi Jim

 

what do you mean I will need a separate HACCP? I am confused. We are a manufacturer that buy in ingredients to produce our product. its the supplier of the food colours we buy that not only produce the colours, they buy some in and repack them. We take both kinds from them. The ones they manufacture and the ones they buy in.

 

The supplier themselves have BRC v7 FS, are you saying that they would also need BRC for agents and brokers?

 

thanks

I think that your supplier only needs its BRC v7 FS certificate. BRC agents and broker Scope scope only includes:

Hi Everyone.

So if you are A and your Supplier/Distributer is B with BRC FS Issue 7 and their Supplier/Product manufacturing plant is C, C would need to be GFSI or be approved through third party audits or questionnaires(depending on level of risk determined by company A), unless company B has BRC for agents and brokers, company A does not need to issue questionnaires or have GFSI or audits from company C.

this was my understanding. please correct me if I am wrong.

What we have been doing sometimes, lets say as company A is asking for the recall procedure or mock recall conducted by say company  B or C to test traceability of product. I have done mock recalls of several products from suppliers who only have questionnaires by selecting a random lot with the last 4 months but I'm sure the auditor will find faults with that too.

Hi Anika,

I'm not exactly sure what yr question was in respect to "A",  but i do believe that Traceability is only necessary for 1step up or down.

Hi Charles,

I'm referring to section 3.5.1.3

"Where raw materials are purchased from agents or brokers, the site shall know the identity of the last manufacturer or packer, or for bulk commodity products the consolidation place of the raw material. Information to enable the approval of the manufacturer, packer or

consolidator, as in clause 3.5.1.2, shall be obtained from the agent/broker or directly from the supplier, unless the agent/broker is themselves certificated to the BRC Global Standard for Agents and Brokers"

By 'LAST MANUFACTURER' I don't know whether they mean the last one or the previous one though.

The comment section on the gap analysis of I6 vs I 7 states

"This new clause works on the principle that the same level of assurance should be applied irrespective of whether the raw material is supplied via an agent or broker or directly. It is expected that the information necessary will be provided by the agent or broker.

The intent is to ensure transparency"

Thank you

Anika

 

Hi Charles,

 

I'm referring to section 3.5.1.3

"Where raw materials are purchased from agents or brokers, the site shall know the identity of the last manufacturer or packer, or for bulk commodity products the consolidation place of the raw material. Information to enable the approval of the manufacturer, packer or

consolidator, as in clause 3.5.1.2, shall be obtained from the agent/broker or directly from the supplier, unless the agent/broker is themselves certificated to the BRC Global Standard for Agents and Brokers"

 

 

By 'LAST MANUFACTURER' I don't know whether they mean the last one or the previous one though.

 

The comment section on the gap analysis of I6 vs I 7 states

"This new clause works on the principle that the same level of assurance should be applied irrespective of whether the raw material is supplied via an agent or broker or directly. It is expected that the information necessary will be provided by the agent or broker.

 

The intent is to ensure transparency"

 

 

Thank you

 

Anika

 

Hi Anika,

i think this answers yr query -

F081 - Phased introduction of Clause 3.5.1.3.pdf   91.66KB   158 downloads

The reluctances discussed are hardly surprising  IMO.

Hi Charles,

Seems like BRC is giving us a little bit of a leeway atm. Good to know. :smile:

Since the moment that your supplier, repacks the food color after buying it, they couldn't be included on the scope of BRC Agents and Brokers and that product would be included on the scope of BRC FS v 7.

Hi Maltus,

Yr comment seems a logical interpretation to me assuming  "repack" means any activity which alters the "presentation" of the received/stored/shipped material (Module 8 [see below] does reference Primary packaging [Hmmm]) .

@Whitney - As per yr  Post 9, and above quote, the supplier you mention is probably from your POV not a broker for the relevant  item "abc"  . So, assuming that "abc" was  included in the scope of B's BRC7 certificate, the latter would presumably suffice.

Note that, If B did no repacking, B presumably  would be regarded as a broker for "abc".  Four options would then seem (to me) to be available to B -

(i) B could choose to  include  "abc" within scope of B's BRC7 certificate via Module 8  (see posts 15-16)

(ii) B could decline option (i) which  would result in "abc" being specifically excluded from B's BRC7 scope (see text Pg2, module 8),

(iii) B could get further certification to Broker Standard for item "abc",

(iv) B could take no further action regarding "abc"

The crux of A's BRC7 certification and involvement with steps (i - iv) would then be as required to fulfill the details noted in this post -

http://www.ifsqn.com...indpost&p=95400

However, the "sensitivity" of some aspects of the above has resulted in  a (temporary?) deferral of the full requirements, see the attachment of post 21.

PS - Note that this thread partially overlaps this parallel thread -

http://www.ifsqn.com...nts-or-brokers/