Sanitation verification from suppliers

Hello all,

I am in the QC/QA field for food oil reprocessing. Does anyone have the requirements for FSMA that states we have to have a letter of good standing from our supplier of drums, which tells us the packaging is food grade. We will be going to SQF soon. Do they also require it? 

Hi, sirgumby;

Yes, SQF requires raw materials validation: 

2.3.2.1 Specifications for all raw and packaging materials, including, but not limited to ingredients, additives, hazardous chemicals and processing aids that impact on finished product safety and quality shall be documented and kept current.

2.3.2.2 All raw and packaging materials and ingredients shall comply with the relevant legislation.

2.3.2.3 The methods and responsibility for developing and approving detailed raw material, ingredient, and packaging specifications shall be documented.

2.3.2.4 Raw and packaging materials and ingredients shall be validated to ensure Product safety and quality is not compromised and the material is fit for its intended purpose.  Validation of raw materials and ingredients shall include certificate of conformance; or certificate of analysis; or sampling and testing.  

2.3.2.5 Validation of packaging materials shall include: i. Certification that all packaging that comes into direct contact with food meets either regulatory acceptance or approval criteria.  Documentation shall either be in the form of a declaration of continued guarantee of compliance, a certificate of conformance, or a certificate from the applicable regulatory agency. ii. In the absence of a certificate of conformance, certificate of analysis, or letter of guarantee, tests and analyses to confirm the absence of potential chemical migration from the packaging to the food contents shall be conducted and records maintained.

2.3.2.6 Product labels shall be accurate, comply with the relevant legislation and be approved by qualified company personnel.

2.3.2.7 A register of raw and packaging material specifications and labels shall be maintained and kept current.

 

Also, any risk based food safety system requires mitigation through various means. If it's not a hazard you are likely to control at any of your processing steps, then you must address this with the supplier, or customer on concession. What this method is will never be entirely well defined by regulation. Generally, the accepted method with regulatory bodies is a few of the following;

Have your suppliers of raw materials approved and registered in some systematic way, and keep something on file renewed periodically such as;

• Letter of conformance/compliance/guarantee
• Certificate of analysis (3rd party analysis is more robust)
• Specification sheets 
• Regulatory registration info
• audit results
• hazard analysis'

I'm assuming these are primary packaging, you don't use any liners?  If so follow what Slab states...if not, then you have to do this for your liners.  Primary packaging materials require this.