This is the BRC7 clause we got one of our NCs.
Though we have risk assessment shown to auditor (it was the RA since our first audit), on this audit he was looking for the conclusion if our raw material is low, moderate or high risk. on our risk assessment no conclusion including the supplier. I've shown him the Supplier Risk Categorization (accepted as CA last audit) but he did not honor it now. We have supplier performance monitoring but we don't have procedure to show how we do it.
I attached our risk assessment for correction and criticism, for us to have the comprehensive and conclusive RA for RM, packaging, additives and their suppliers.
3.5 Supplier and raw material approval and performance monitoring
3.5.1 Management of suppliers of raw materials and packaging
Statement of Intent The company shall have an effective supplier approval and monitoring system to ensure that any potential risks from raw materials (including packaging) to the safety, authenticity, legality and quality of the final product are understood and managed
220.127.116.11 The company shall undertake a documented risk assessment of each raw material or group of raw materials including packaging to identify potential risks to product safety, legality and quality. This shall
take into account the potential for:
• allergen contamination
• foreign-body risks
• microbiological contamination
• chemical contamination
• substitution or fraud (see clause 5.4.2).
Consideration shall also be given to the significance of a raw material to the quality of the final product.
The risk assessment shall form the basis for the raw material acceptance and testing procedure and for the processes adopted for supplier approval and monitoring. The risk assessments shall be reviewed at least annually.
18.104.22.168 The company shall have a documented supplier approval and on going monitoring procedure to ensure that all suppliers of raw materials, including packaging, effectively manage risks to raw material quality and safety and are operating effective traceability processes. The approval and monitoring
procedure shall be based on risk and include one or a combination of:
• certification (e.g. to BRC Global Standards or other GFSI-recognised scheme)
• supplier audits, with a scope to include product safety, traceability, HACCP review and good
• manufacturing practices, undertaken by an experienced and demonstrably competent product safety auditor
or, for suppliers assessed as low risk only, supplier questionnaires.
Where approval is based on questionnaires, these shall be reissued at least every 3 years and suppliers will be required to notify the site of any significant changes in the interim.
The site shall have an up-to-date list of approved suppliers.