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Defining exceptions to the supplier approval process

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aeb11

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Posted 16 August 2018 - 12:24 PM

Hello everyone  :biggrin:

 

I was hoping some one could give me some guidance on section 3.5.1.7 of BRC Standard 8. 

I work for a company that produces nutritional supplements (powders, capsules, tablets...) and we have our first BRC audit soon! I've only been in my role as Quality Manager since July, so please bear with me.

 

Many of our customers will issue materials for us to include in their products that we manufacture. In 3.5.1.7 is states that procedures shall define how exceptions to the supplier approval processes in clause 3.5.1.2 are handled (e.g where raw materials are prescribed by a customer). 

 

However it doesn't tell me how to go about this? 

 

Any advice would be greatly appreciated.

 

Thanks

Amy

 



Scampi

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Posted 16 August 2018 - 01:46 PM

Welcome Amy

 

You need to include a statement in your supplier approval program that speaks specifically to private label/co-packing that those ingredients shall be sourced by the owners of the product and that the product owner is responsible for using products that appropriate for the finished goods; and that your facility will ensure that those ingredients do not pose a hazard to YOUR OWN products.  (i.e allergen management, or cross contamination) so wash down between finished goods etc

 

or something like that

 

Hope that helps


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aeb11

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Posted 16 August 2018 - 03:00 PM

Thank you :D I was wondering at one point if it could be something along those lines but really was not confident if I was right or not and do not want to get it wrong.

 

You've been a great help :)

 

Amy



pHruit

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Posted 16 August 2018 - 03:03 PM

Hi Amy,

Broadly in line with Scampi's suggestion, we have a clause in our supplier approval procedure stating that any source that doesn't satisfy the full requirements we've defined will be handled via our concession process. There is then an individual concession record for each case, clearly showing the relevant considerations.
You may also want to set minimum requirements for these types of ingredient as whilst you may be able to clearly record that the customer is responsible for due diligence in purchasing, you'll still need to satisfy your own site and processing requirements - probably therefore want the spec, allergen details, storage/shelf life, GMO information, safety data sheets (if applicable) etc as a minimum, plus possibly HACCP (if preliminary processing may have a bearing on your own processing), certification for the actual supplier etc.

If possible it's potentially useful to have these concessions signed both by your business and by your customer, as it demonstrates your own considerations with regard to your procedure, and that the customer understand their responsibilities and obligations.



Scampi

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Posted 16 August 2018 - 06:23 PM

Be VERY clear in your statement to include something that separates YOUR product from product you make FOR OTHER COMPANIES, you may actually want 2 separate procedures

 

It may be worth running your product on a different day then the co-pack products as a way of segregating as well


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aeb11

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Posted 17 August 2018 - 07:16 AM

This is all really useful advice guys  ^_^

We have mixture of customers supplying all the raw materials or only some so we have to supply the rest and where they supply none of them so I can get something drawn up to cover this now. 

Thank you  :lol:

 

Amy



dani2511

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Posted 13 September 2018 - 10:03 AM

Hi Amy,

 

You will still need to conduct some sort of Risk Assessment for your facility - request Specs, MSDS documents, Allergen Statements, Kosher/Halal (if these are applicable to your facility), etc. I think it would also be prudent to check the customers formulation and label claims to see if they are using the correct conversion factors (that you're not overdosing on iodine, selenium, iron, etc). You can provide your customer with a statement that they need to sign saying that they take full responsibility for the end product and label claims so that you shift the responsibility over. Do you issue your own production specs for their products? Perhaps it's something you can include in a footnote on sign off?

 

Dani



KarrieC

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Posted 09 December 2021 - 07:47 PM

We co pack product.  We do not own the product or any of the materials used for packaging.  I have a vendor approval program for our cleaning supplies, maintenance chemicals, and service contractors.  The auditor said I had to approve our raw material and packaging supplies.  We have no say in the source of these items as they are shipped to us by our customer.  I did write up a paraph explaining that we were only responsible for reporting and rejecting anything that arrives in unsanitary conditions.  It seems like he's asking me to approve our customer.  



pHruit

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Posted 10 December 2021 - 08:48 AM

If you haven't already done so, you should definitely review the Interpretation Guide for section 3.5.1.7.

The intent of the "exception" process isn't to allow you to totally abdicate all responsibility for supplier and raw material controls - for example, it makes the very valid point that you need to ensure that you can assess and control the risks these might pose to other products.

 

Whilst the IG doesn't define the nature of an "exception", I think it is a reasonable inference to conclude that this is intended for occasional use, and therefore shouldn't/couldn't be applied to *all* raw materials.

 

Have you tried discussing with your customers? Having previously done contract packing where the situation was the same as yours, i.e. none of our own raw materials, I didn't have many issues getting BRC or equivalent certs, product spec, allergen info etc for each raw material. Particularly when I told customers that I couldn't reasonably accept their materials onto site without this, and so would be forced to turn their deliveries away, and potentially charge them for the missed production slot that would result from this ;)

Obviously I'd suggest starting on a somewhat less pushy footing - explain why you need this, for example allergens are an easy one as no customer is going to want to recall their product because a different customer forgot to tell you they had nuts in a raw material, so they should be able to relate to this and understand why it's a reasonable request.





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