BRC Issue 2 Storage and Distribution - Am I in scope?

I've recently moved from my previous job to a new job (yay me!).

Before, we were certified as a manufacturing site under BRC Issue 7. 

This place is looking to implement a quality management system and I'm familiar with BRC, so I'm leaning that way.

The thing is we own product and have people label product and we distribute product, but we physically touch NONE of it. 

Every single thing is handled through 3rd party logistics warehouses.  All activities are outsourced.

I'm looking through the standard and it LOOKS KINDA like our operation would be in scope, but it is obviously WAY MORE focused on someone who OWNS and OPERATES a warehouse rather than someone who uses rental warehouses.

Help me Obi Wan Kenobi, you're my only hope.

JPO :helpplease:

Hi JPO,

Sure sounds like storage and distribution, you say you own the product, where does it come from?

Kind regards,

Tony

Hi JPO,

 

Sure sounds like storage and distribution, you say you own the product, where does it come from?

 

Kind regards,

 

Tony

Here's the scenario: 

The company I work for goes hither and yon, seeking unique, innovative, and qualifying for certifications like organic, fair trade, ecosocial, gluten free, non-gmo verified, (insert trademarked logo here).   

So, they cater to the high end specialty market who wants to market those characteristics to their customers.

We purchase the products from the manufacturers (sometimes with our brand name, sometimes with their brand name).  These products are loaded on container ships and sent from the far reaches of the world to the United States.  They are then offloaded, clear customs, and are trucked to contract warehouses.  The warehouse may or may not label the product for us (overlabel existing containers, no repackaging).  The warehouses receive the material, store the material, pick and ship the material at our direction, and receive any returns.

We contact the materials sold exactly 0 times during the chain of custody from the manufacturing step through the final delivery and acceptance at the end user.

So, while we ARE in the business of distribution, all storage is done off site by contracted warehouses.  All actual physical distribution is done off site by contracted warehouses.

My thoughts are if we DO decide to go for BRC Issue 2 certification (or any GFSI certification) or simply build the food safety management system around the BRC standard without going through with the actual certification, I'm going to be in a position where I'm managing 9 different offsite warehouse's businesses or at least am in the position where I have to send them standards for what is expected AND get my butt out there and audit them to ensure they are doing things in a manner that is consistent with the standard.

Sort of similar to if you have a contract manufacturer, you need to ensure they are following the same standards you would expect if you were doing the manufacturing yourself.

Comments?  Advice?  Is this thing on?

Then I think you are Agents and Brokers ...... and should build your fsms around the BRC standards without going through with the actual certification unless your customers expect you to have a certified system.

Kind regards,

Tony