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Best Answer , 07 April 2016 - 09:18 PM

Hi Anika ,

 

Yes , you are right .

COA is for product , and it is batch specific ,so it is for each batch or lot not only once .

COA :〈food safety〉 document provided by the supplier which indicates results of specific tests or analysis, including test methodology, performed on a defined lot of the supplier’s product ( ISO 22002-1)

it is required in 9.2,9.3 ISO 22002-1

 

In this case  we have different systems ,no inter-company supply will not help since system is not integrated or unified between different plants , you are like different plants with different schemes , you should follow ( BRC 3.5.1.1 and 3.5.1.2) and  9.2,9.3 ISO 22002-1

 

So I think if you need ( according to BRC 7 and FSCC ) :

- Copy of the GFSI certificate .

-COA sent with each batch.

-A successful site audit which as a minimum covers product safety, traceability, HACCP and good manufacturing processes. This audit must be completed by an appropriately experienced and

competent auditor (i.e. someone who has completed training in auditing techniques and with experience of auditing, and knowledge of the product, ingredient or processes being audited).
Non-conformities should be addressed (e.g. in an agreed action with timescales) unless they are critical to product safety or legality, in which case supply should not be permitted until nonconformities
have been satisfactorily addressed.
 
Best regards ,
Ehab 
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Anika

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Posted 07 April 2016 - 01:42 PM

Hi everyone!

 

I wasn't sure under which topic this should be so mods, please switch it over if need be.

 

Our company has been purchased by another last year and now parent company wants to bring in their confectionary items to ours and we would be re-packing/co-packing them. Should we consider them a supplier then and have Supplier approval for them as well? We have BRC and they have FSSC 22000 but other than the Quality audit, in terms of documentation in general, what do you guys think?

 

Parent company is not in Canada btw and legally, we still have two separate names. CEO's are different but the board resides over both.

 

Thank you in advance!



Ehab Nassar

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Posted 07 April 2016 - 03:04 PM

Hi Anika ,

 

So your company (as you are now one company)  has two factories , one factory will send confectionery in bulk to be packed in the other , if this is the situation , I will consider it as an inter-company supply , and a SOP may be in place with the inter-company supply agreement  ,  If the two plants are aligned with the same system and same certification it will be perfect , you can easily state that the company has the same system and same certificates , and then your inter company supply SOP will  stat you have the same system so the COA as will as the release decision document which is sent with the product is considered as a release criteria for you and you will focus on the defects that may occur during transportation ( e.g. temperature abuse , handling , orgnoleptic evaluation ,... ) .

 

If you have different systems I think you should collect all data that proof that it is safe and consistent product as it is a foreign supplier unless you have a documented evidence , like an approval from Regional QA or QA director based on documented assessment , use a 3rd party audit or any suitable method .

 

N.B.

Intercompany policy and procedure : The policy outlines procedures for intercompany transactions defined as accounting transactions that occur between two or more locations within a company

 

Best Regards,

Ehab



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Anika

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Posted 07 April 2016 - 03:19 PM

Hi Anika ,

 

So your company (as you are now one company)  has two factories , one factory will send confectionery in bulk to be packed in the other , if this is the situation , I will consider it as an inter-company supply , and a SOP may be in place with the inter-company supply agreement  ,  If the two plants are aligned with the same system and same certification it will be perfect , you can easily state that the company has the same system and same certificates , and then your inter company supply SOP will  stat you have the same system so the COA as will as the release decision document which is sent with the product is considered as a release criteria for you and you will focus on the defects that may occur during transportation ( e.g. temperature abuse , handling , orgnoleptic evaluation ,... ) .

 

If you have different systems I think you should collect all data that proof that it is safe and consistent product as it is a foreign supplier unless you have a documented evidence , like an approval from Regional QA or QA director based on documented assessment , use a 3rd party audit or any suitable method .

 

N.B.

Intercompany policy and procedure : The policy outlines procedures for intercompany transactions defined as accounting transactions that occur between two or more locations within a company

 

Best Regards,

Ehab

Thank you Ehab!

 

If I use the Gap analysis to draw the differences out between FSSC 22000 and BRC and incorporate it on the SOP you mentioned, would it be a reasonable in terms of Quality documentation? Since both companies are certified under two different GFSI recognized scheme, would one COA work? My understanding is COA is for the product itself irrespective of the company.

 

Product spec, allergen, nutrition, kosher/halal, e.t.c should still be from the manufacturing company right?

 

The approval from regional qa or director based on documented assessment, did you mean risk assessment?

 

Thank you so much,

Anika



Scampi

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Posted 07 April 2016 - 04:54 PM

HI Anika

 

There are many changes afoot (safe food for Canadians act and regulations) that will be (supposed to be) implemented by 2018 at the outside. I would err on the side of caution and state the other locations as a foreign supplier. 

Here's a link to a summary of the import changes to the confectionery industry, may or may not apply depending on your ingredients.


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Ehab Nassar

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Posted 07 April 2016 - 09:18 PM   Best Answer

Hi Anika ,

 

Yes , you are right .

COA is for product , and it is batch specific ,so it is for each batch or lot not only once .

COA :⟨food safety⟩ document provided by the supplier which indicates results of specific tests or analysis, including test methodology, performed on a defined lot of the supplier’s product ( ISO 22002-1)

it is required in 9.2,9.3 ISO 22002-1

 

In this case  we have different systems ,no inter-company supply will not help since system is not integrated or unified between different plants , you are like different plants with different schemes , you should follow ( BRC 3.5.1.1 and 3.5.1.2) and  9.2,9.3 ISO 22002-1

 

So I think if you need ( according to BRC 7 and FSCC ) :

- Copy of the GFSI certificate .

-COA sent with each batch.

-A successful site audit which as a minimum covers product safety, traceability, HACCP and good manufacturing processes. This audit must be completed by an appropriately experienced and

competent auditor (i.e. someone who has completed training in auditing techniques and with experience of auditing, and knowledge of the product, ingredient or processes being audited).
Non-conformities should be addressed (e.g. in an agreed action with timescales) unless they are critical to product safety or legality, in which case supply should not be permitted until nonconformities
have been satisfactorily addressed.
 
Best regards ,
Ehab 
-


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Charles.C

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Posted 08 April 2016 - 12:16 PM

HI Anika

 

There are many changes afoot (safe food for Canadians act and regulations) that will be (supposed to be) implemented by 2018 at the outside. I would err on the side of caution and state the other locations as a foreign supplier. 

Here's a link to a summary of the import changes to the confectionery industry, may or may not apply depending on your ingredients.

 

Hi scampi,

 

i don't see any Link ?


Kind Regards,

 

Charles.C


Scampi

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Posted 08 April 2016 - 05:41 PM

Whoops.

Here it is

http://www.inspectio...82343_eng.pdf. 

Enjoy some light reading for the weekend!


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