Acceptance by Concession
Hello all, I'm fairly new to the industry and could use some guidance. I work with nuts and all product processed at our facility are for further processing. On occasion we get non-conforming products that can be made safe again through further processing. Due to the nature of the industry I thought it may be good to create a special release procedure that includes an Acceptance by Concession document to ensure that the buyer knows they must further process, execute a kill step, and pretty much ensure they assume the risk upon purchase. Could anyone offer advice on information/important statements to include or provide examples. My biggest fear is not asking for enough information or overstepping bounds.
I've got the following list going so far:
- Supplier Information
- Buyer Information
- Contract Information
- Lot Number
- Quantity
- Description of non-conformity
- Cause of non-conformity
- Disposition
- Cost to acquire to be - increased, decreased, unchanged
- Approval for QA, Sales, and Manager
Thanks for the help!
Hello all, I'm fairly new to the industry and could use some guidance. I work with nuts and all product processed at our facility are for further processing. On occasion we get non-conforming products that can be made safe again through further processing. Due to the nature of the industry I thought it may be good to create a special release procedure that includes an Acceptance by Concession document to ensure that the buyer knows they must further process, execute a kill step, and pretty much ensure they assume the risk upon purchase. Could anyone offer advice on information/important statements to include or provide examples. My biggest fear is not asking for enough information or overstepping bounds.
I've got the following list going so far:
- Supplier Information
- Buyer Information
- Contract Information
- Lot Number
- Quantity
- Description of non-conformity
- Cause of non-conformity
- Disposition
- Cost to acquire to be - increased, decreased, unchanged
- Approval for QA, Sales, and Manager
Thanks for the help!
Hi amorable,
IMO a little more context is necessary to get relevant answers, eg the product / specific nonconformance(s) referred and perhaps their magnitude.
Yr query IMO potentially overlaps a variety of issues, not just a solely commercial one. For example -
(1) Is the nonconforming product under discussion legally allowed to be commercialised ? This presumably will relate to the specific hazard/specific future intentions, eg onward processing..
(2) Assuming legality is not an issue, Is yr buyer willing to accept product which is acknowledged as non-compliant in some safety-related aspect with its specification ? Same additional comment as for (1) above.
(3) Same as (2) but "non-safety" replacing "safety".
(4) Does yr OP overlap maintaining certification to any particular FS Standard ?
(5) How do you intend to document this "manouevre" in yr HACCP Plan ? (assuming you have one).
Just as an example, IMEX (not nuts) some raw finished products like meat are tacitly assumed to potentially contain low levels of microbial pathogens like salmonella. Such raw products if retailed are labelling stipulated to require a cooking process which can be assumed capable of "eliminating" such a pathogen. Net result is that the product can be risk-assessed/HACCCP designated as Low Risk from a haccp POV.
If sold as an intermediate product the haccp plan for the receiver's onward processing to RTE will typically note the aforementioned pathogen in their hazard analysis and the subsequent cooking process will be designed accordingly.
The details of above analysis will depend on the specific hazard of course.
So all product leaving our facility is labeled as "for further processing". We do not sell directly to the public, only to other processing facilities. There was a detectable amount of micro in the product. Micros are in our HACCP and are known and accepted due to the fact that the nut is harvested off of the orchard floor. The product can be rendered safe with an effective kill step. I was thinking to develop a special release procedure that will allow the release of product deemed non-conforming by typical standards. Released to be authorized by QA, director, and sales. Special release to include written agreement between ourselves and buyer clearly showing they have been made aware of the products status and are aware that they must further process the product to render it safe for consumers. Hoping I'm not too far off in left field with this!
We are BRC certified. I'm using clause 3.8.1 regarding non-conforming products. One of the line items is "defined responsibilities for decision making on the use or disposal of products appropriate to the issue (e.g. destruction, reworking, downgrading to an alternative label or acceptance by concession" as my main guide at the moment.
The buyer is aware and willing to accept however I am struggling to ensure that I take every precaution to protect ourselves and comply with rules and laws out there.
Hi amorable,
So what are yr Product Specification/haccp criteria/actual data which are causing you to regard yr product as "non-conforming" ?