Verification of claims BRC section 5.4.4 - Manuka Honey

Hi All,

I was hoping for some advice on closing a CAR out against BRC section 5.4.4.

The NCR was “Not all provenance claims were able to be specially verified by batch”.

This NCR was in relation to our use manuka honey as an ingredient and it being mentioned on front of pack.

Previously it has been enough for us to provide the raw material specification and an addition statement from the supplier which states the product is manuka honey.  

Anyone have any suggestions on what more I can do to satisfy the requirement of section 5.4.4?

Additional info:

- The supplier is not GFSI certified.

- The honey we buy is a spray dried honey.

- The only claim we are making it that the product contains manuka honey or is manuka honey flavoured. 

- We are based in Australia and the manuka honey is also from Australia.

Thanks in advance.

Douglas

Hello Douglas,

If you can do suppliers audit, some calls it surveillance audit, has to visit them. The scope must include traceability. If your supplier is a trader, the product must be tarceable to its manufacturer. On your manufacturing plant, it must be shown to auditor that during receiving until it is being shipped you do not loss it traceabilty.

You have to justify that the claim you made is true.

regards, 

redfox

Hi Douglas,

Manuka Honey is an unfortunate one to get picked up on. Every briefing, seminar, training, guidance document I've seen here in the UK cites Manuka Honey as an example of a product with significant authenticity issues. I've not seen any substantiation of it, but the "fact" that usually accompanies this is that the UK market alone buys more Manuka honey annually than is produced globally, so not surprised to see that there is some focus on this.

What does your vulnerability assessment currently say about the risk status of this ingredient?
Unfortunately to me it looks like it would be difficult to justify as low risk - The Manuka has a specific claim, is from a non-GFSI source, is in a form in which it easy to hide adulterants, and has a documented history of authenticity problems.

I can see why the auditor hasn't considered a statement to be enough on its own - it's easy to write a statement (arguably more so if intentionally misleading the customer for commercial gain ;) ) and indeed this is part of where this section of BRC originates from.

In your position I'd look at this in two parts:
1) Your own site controls:

Is it booked in as generic "honey", or specifically as "Manuka Honey"?
Does the supplier clearly label it as Manuka, and is this checked and recorded on receipt at your site?

Is a similar record made when it's allocated to, and used in, production?

Do you have a periodic mass balance exercise to verify that you haven't used more Manuka than you've received? (Probably needed as part of the six-monthly one mandated under 5.4.4).

2) The supplier / raw material, i.e. what measures can you take to assure yourselves that what you are receiving is really Manuka honey, not a cheaper generic honey?

We handle a lot of juice products and are in a broadly similar position where some of these make a claim - well-known history of adulteration and easy to hide adulterants.

Generally we'd use a two approaches together. First I'd suggest a traceability exercise with your supplier, back to source to verify that what is going in really is Manuka honey. You may need to repeat this on a periodic basis, and since BRC loves a risk assessment you'd probably be in the strongest position if you did one to decide this frequency.

Secondly, there is various analysis available that looks for the levels of certain key components in honey samples, and compares these to datasets of known authentic Manuka. For example, see: https://www.fera.co....tosperin-1.html

It's likely that a more local laboratory would be able to offer something similar.
You could also look at combining this with some C4 analysis as this would potentially tell you whether the honey (whatever sort it is) has been adulterated with exogenous sugars, although this is likely to be more complex if any carriers/additives have been used in the spray drying process. I'd do a bit of a search for labs in Aus/NZ and get in touch to discuss what they may be able to do with the dried product.
Can't hurt to also ask your supplier if they have any analysis etc that would help.

Hi Redfox / pHruit,

Thank you for taking the time to respond. I really appreciate it!

I was thinking that an audit might be necessary, but they are unfortunately on the other end of the country and we do not buy a lot from them, so I will try and leave it as a last resort.

We don’t currently do any mass balance exercises on this raw material, but I will try that approach fist to see it that works.

I have also looked at testing, but with it being powdered blend it rules out all the normal testing. 

I will let you know how I go.

Thanks

Douglas

Hello Douglas,

Be prepare about foreign supplier. That is our NC on our last audit. Though it is primary packaging supplier, they require us to audit the supplier because it is not GFSI scheme certified. Non-GFSI certified site can not be considered low risk supplier. So, it can not be issued a SQA only. Our corrective action is revised our procedure in Supplier Approval Procedure and on-going monitoring. It is stated there that we conduct audit to our foreign supplier. Luckily we have our BRC7 certificate. 

regards,

redfox