3.5 Supplier and Raw material approval and performance monitoring
Hi All,
Our manufacturing site has been recently audited and one CAR raised on clause 3.5. During the audit, we have requested to provide MRL result for both pesticide and heavy metal for fresh vegetables (onion and cauliflower) and dry spices (fennel seed, chili powder, mustard seed)
We found very difficult to get the MRL result for pesticide and heavy metal test from the supplier due to following recent:
- They are distributor.
- They are not BRC approved site
- The test result for Pesticide and Heavy metal residue is very expensive (about AUD$500)
For vegetables supplier; they only have MRL on pesticide but not heavy metal. on the other hand, for dry spices, we are dealing with distributor, and they are an imported spices.
Question:
- Do we have to actually test for heavy metal as well? as per my knowledge only pesticide is required.
- Is there any way to get away from this clause?
appreciate your thought on this.
Regards,
Felicia
Hello Felicia,
That was our NC when we were audited because our supplier of additives couldn't provide us the requirement we requested from them.Our corrective action is to replace the supplier and find one that can furnish us the documents required by BRC. Cost is not accepted by auditor why supplier can't give the parameters they wanted suppliers must produce to their buyers.
regards,
redfox
Hello redfox,
Thank you for your thought. Yes, it is very difficult to ask this information from the supplier especially when we are dealing with distributor and cost is becoming an issue for them.
regards,
felciia
Hello redfox,
Thank you for your thought. Yes, it is very difficult to ask this information from the supplier especially when we are dealing with distributor and cost is becoming an issue for them.
regards,
felciia
Hi felicia,
Wrong Forum ?
I assume the discussion is oriented to BRC7 Standard.
There hv been some literature suggestions that earlier versions of BRC FS Standards under-emphasised the importance of "Supplier Approval". The last few years have seen BRC’s response to such comments such as in sec. 3.5.
This is in the BRC7 intro. -
The Global Standard for Food Safety has been developed to specify the food safety, quality and operational criteria required to be
in place within a food manufacturing organisation to fulfil obligations with regard to legal compliance and protection of the
consumer.
PRINCIPLES OF THE GLOBAL STANDARD FOR FOOD SAFETY
A food business must have a full understanding of the products produced, manufactured and distributed, and have systems in
place to identify and control hazards significant to the safety of food. The Global Standard for Food Safety is based on two key
components: senior management commitment and a HACCP-based system (which provides a step-by-step approach to
managing food safety risks)
.
From a BRC auditor's POV, yr specific query overlaps FS elements such as legal responsibility for one's product, Product Specifications, Risk Assessment, significant hazards, scope of haccp plans.
A BRC auditor might expect to see evidence, for example, as to why you seemingly regard heavy metals/pesticides as not significant hazards. If you can justify such, then no need to detail in the haccp plan. (Conversely perhaps BRC should also be able to validate the rebuttal of an opinion of non-signifcance). One common evidential support (either-way) is via History/Official surveys.
It's ultimately usually all about RA significance (eg theory/History) and related validatory data (yours or other people's).
PS - have there been any local official surveys of these industries which covered the HM/Pesticide aspects ?
Hi Charles,
Apologize if I posted in the wrong forum. yes it does related to BRC version 7.
Thank you for your recommendation. I'll review the risk assessment and see how it goes.
regards
Felicia
Hi Charles,
Apologize if I posted in the wrong forum. yes it does related to BRC version 7.
Thank you for your recommendation. I'll review the risk assessment and see how it goes.
regards
Felicia
No problem. Shifted.
The fresh product area will always be tricky IMO since no process micro. killing steps and primary production areas sometimes "under the radar". Various incidents elsewhere, eg pathogenic E.coli have publicised the FS aspect for first commodity in recent years.
2nd general category (raw[?] spices) has from memory a long chequered FS history already.
IIRC Australia does publish numerous industry-wide surveys of food categories (for Stakeholder purposes also).
Does yr Veg. Product Spec. refer to HM/Pesticides or simply the customary catch-all - "relevant local Regulatory requirements" ? :smile:
(I am vaguely curious why BRC homed in on these 2 items since do not recall seeing any particular related incidents in Australia ? )
Hi Charles,
It is always challenging when dealing with raw material supplier. especially if they are distributor and the ingredient is an imported product. They are supposed to provide the information however MRL pesticide and heavy metal testing result are not common compare to micro result. In addition; it is depend on food safety certificate that they are comply with. We do have standard acceptance procedure that require all our raw material supplier at least hold HACCP (JASNZ) certified.
I am surprised myself why this issue get picked up during the audit. I thinks the issue is more to chemical hazard that has been incorporated into HACCP plan does not really describe the hazard which is associated with raw material supplier. The audit is over and non-conformance is raised. I have to demonstrate in such a way that the MRL pesticide and heavy metal of the raw material are in compliance. There is actually an easy way to demonstrate by testing the finished product which all of this ingredient went into. However this will be our last option to go for.
Yes I am agree with you; so far there hasn't been any critical incidences with regard to pesticide and heavy metal contaminant in Australia.
Finger crossed I can get all sorted before the due date.
Have a good day
Cheers
Felicia
Hi Felicia,
out of curiosity, i did a little googling.
Current items (2016) like this one may be the root cause for the auditor intererest -
http://www.abc.net.a...eptable/6585300
Or perhaps the various caveats in this, otherwise fairly positive, report (2014) -
Hi,
I am a new member form Vietnam
I think you should ask the distributor/importer to request the producer (additive, ingredient,...) the testing. Not so often but for verification, once per year is enough. The producer's always having their program to verify their product according to their food safety legislation.
We are in Vietnam and most of ingredient we import. And the importer should get the test from producer at the first batch. Of course, depend on risk, they require the test more or at least once a year
This is how we do to comply with legislation/auditor
Best regards
Vo Po Ri