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How to challenge a suppliers traceability?

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Gilles

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Posted 19 December 2017 - 10:39 AM

With the BRC demands to challange a suppliers traceability I see this often appering in customer questionnaires.

 

But how does one challenge a suppliers traceability?

 

If I would send a random trace test no customer would ever understand it.



GMO

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Posted 19 December 2017 - 01:41 PM

Oh please don't start asking your customers for traces unless you really need to.  Some days we get two a day.  With BRC everything is risk assessment so if they're certified to a GFSI standard, they've had their traceability challenged.  If they are audited for authenticity purposes, they've had their trace challenged. 

 

As for understanding it, when / if you do need to do it, just do a summary page or get the supplier to fill one in.



Gilles

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Posted 19 December 2017 - 02:11 PM

No I am not planning on doing this but we have a new customer who requires us to do it for suppliers who are not GFSI certified.

And because we have some I am checking if there even is a good way to challenge their traceability or if we just will not comply with his demands



FurFarmandFork

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Posted 19 December 2017 - 04:10 PM

No I am not planning on doing this but we have a new customer who requires us to do it for suppliers who are not GFSI certified.

And because we have some I am checking if there even is a good way to challenge their traceability or if we just will not comply with his demands

If they're not certified then it may make sense to perform basic checks. Though if they're certified under any standard that includes a trace activity I would consider that appropriate.

 

Perhaps a copy of their recall plan would also suffice and require much less work of your suppliers.


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Madam A. D-tor

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Posted 22 December 2017 - 09:53 AM

Only a traceability test is not hard to conduct these days.

Most companies do have a digital system, which makes it very easy to conduct traceability tests.

 

I think within the B2B we should conduct very simple traceability verification.

Give your supplier a product code or reception date, or whatever you use and ask him if he can tell you:

- when it was produced;

- where it was stored;

- who transported it;

- when the major raw material of this product received and if your supplier knows for 100% sure, who is the supplier of this material;

- when the minor raw material of this product received and if your supplier knows for 100% sure, who is the supplier of this material.

 

All other things that you put in your internal traceability test or vertical auditing are not relevant to know from your supplier. You do not like to know his total mass balance, all the specifications of the raw materials, the supplier assessments of all involved suppliers, the training records of staff involved, etc., etc..

if you had a major complaint to your supplier, in which it was needed to trace to raw material of supplier, I will consider this as sufficient.

 

Please be aware that you have selected your suppliers on specific requirements. Following BRC this will be:

- GFSI certificate;

- audit covering traceability, HACCP, hygiene, etc. conducted by experienced auditor  ( this makes it possible to also accept other food safety certificates, e.g. ISO 22000, all these items are included in ISO 22000 audits and ISO 22000 audits are conducted by trained and skilled auditors)

- supplier questionnaire (but only if the supplier is low risk)

For suppliers approved on questionnaire every 3 years the traceability should be verified.

 

Mostly there are already questions related to traceability in this questionnaire. So, if you approve the supplier, you know that they have a system for traceability.

The verification of the effectively of this traceability system should not be that hard.

I think that I (if I was a QA manager in your position) would even accept a summary/conclusion of the latest traceability test, the supplier performed. Not all the related documents. Just a simple report, with conclusion and simple mass balance. I would not want to look into all the evidence of the test the supplier had conducted.


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Madam A. D-tor

garycreasey

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Posted 22 December 2017 - 01:19 PM

Hi,

 

The draft version 8 of BRC requires a traceability procedure that includes as a minimum how the traceability system works & the labeling & records required.

So hopefully moving forward for those of your using BRC as an approval method this wold suffice for audit purposes.

 

Could be a while before it gets issued though.

 

Gary

Quality Manager, UK



Madam A. D-tor

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Posted 22 December 2017 - 01:26 PM

Dear Gary,

 

As far as I can see, BRC issue 8 (draft) has not changed the requirement related to traceability verification of suppliers approved by questionnaire.


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Madam A. D-tor

GMO

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Posted 27 December 2017 - 10:23 AM

Only a traceability test is not hard to conduct these days.

Most companies do have a digital system, which makes it very easy to conduct traceability tests.

 

I think within the B2B we should conduct very simple traceability verification.

Give your supplier a product code or reception date, or whatever you use and ask him if he can tell you:

- when it was produced;

- where it was stored;

- who transported it;

- when the major raw material of this product received and if your supplier knows for 100% sure, who is the supplier of this material;

- when the minor raw material of this product received and if your supplier knows for 100% sure, who is the supplier of this material.

 

All other things that you put in your internal traceability test or vertical auditing are not relevant to know from your supplier. You do not like to know his total mass balance, all the specifications of the raw materials, the supplier assessments of all involved suppliers, the training records of staff involved, etc., etc..

if you had a major complaint to your supplier, in which it was needed to trace to raw material of supplier, I will consider this as sufficient.

 

Please be aware that you have selected your suppliers on specific requirements. Following BRC this will be:

- GFSI certificate;

- audit covering traceability, HACCP, hygiene, etc. conducted by experienced auditor  ( this makes it possible to also accept other food safety certificates, e.g. ISO 22000, all these items are included in ISO 22000 audits and ISO 22000 audits are conducted by trained and skilled auditors)

- supplier questionnaire (but only if the supplier is low risk)

For suppliers approved on questionnaire every 3 years the traceability should be verified.

 

Mostly there are already questions related to traceability in this questionnaire. So, if you approve the supplier, you know that they have a system for traceability.

The verification of the effectively of this traceability system should not be that hard.

I think that I (if I was a QA manager in your position) would even accept a summary/conclusion of the latest traceability test, the supplier performed. Not all the related documents. Just a simple report, with conclusion and simple mass balance. I would not want to look into all the evidence of the test the supplier had conducted.

 

But why test it?  If you are GFSI approved it has been tested.  Even if your trace "only" takes an hour, it's still an hour of about 5-10 peoples time in my business and a waste of money.



Madam A. D-tor

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Posted 27 December 2017 - 07:21 PM

But why test it?  If you are GFSI approved it has been tested.  Even if your trace "only" takes an hour, it's still an hour of about 5-10 peoples time in my business and a waste of money.

If the supplier is GFSI approved certificated you do not need to test it for the BRC standard.

 

Personally I believe that nowadays only traceability, may not take more than 15 minutes. Not the whole stuff with all the issues you can connect to it. Only: when did I produce it, who where the suppliers and where did the product go. Well maybe, 30 minutes, but that is it.


Kind Regards,

Madam A. D-tor

GMO

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Posted 28 December 2017 - 12:43 PM

If the supplier is GFSI approved certificated you do not need to test it for the BRC standard.

 

Personally I believe that nowadays only traceability, may not take more than 15 minutes. Not the whole stuff with all the issues you can connect to it. Only: when did I produce it, who where the suppliers and where did the product go. Well maybe, 30 minutes, but that is it.

 

You're making some very big assumptions there.  For example, you're assuming ingredients are brought on site, processed and sent out within a couple of days.  Not always the case and that can complicate traceability.  I have worked in factories where products have been on site for 2-6 months (cheese), up to 2 weeks (certain gelled confectionery), have multiple batches going into one product flow (sandwiches)... While it's great some factories have their trace that quick nowadays, from the testing I do undertake (which is minimal), I can tell you no-one responds that quickly.  While 4 hours is required for an auditor and a speedy response may be what an auditor gets, that's not the response you'll get as a business to business customer.  Likewise if it's already tested then why test again?  The only reason I do is where a site appears to have limited controls for authenticity or where we've had historical authenticity problems.





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