Will a LOCG suffice or do I neen a COA for every ingredient received?

Hi All,

M first post on this forum so forgive me if i leave out some initial details. I work for a small bakery and I'm currently the only food safety coordinator trusted with taking us to SQF accreditation.

I'm working on our supplier approval program and i can't decide if i need to demand a COA for every ingredient with every shipment we receive.

We receive up to 20 individual ingredients a day as we're fairly high volume, we only have one CCP and that is cooling as our baking temperatures are way above the necessary time/temp combination for product safety. This is monitored and verified by myself via temperature records. 

If anybody who has undergone or solved this issue I would be most appreciative.

Thanks,

Killian

Hi Killian

Welcome

If you have not had an issue in the past, and you are confident in your suppliers than you probably do not need a COA for each shipment, plus it would be an ungodly amount of paperwork that would need verified (and you do not need more paperwork!)

However, you should have a signed agreement from your vendors that stipulates parameters that WILL NOT BE out of spec, this will be a letter of guarantee that you should review and get an updated copy of yearly

so, let's say vanilla extract cannot have more than 35% water by weight or not more than 2.5% vanilin

UNLESS you know you've got an ingredient that is often fraudulent, then you should request of CoA for each shipment

Hi Scampi,

Thank you so much for your response. 

I have the letters of guarantee but maybe i need to look at the wording just to cover. We only have five suppliers, all GFSI audited and no history of messing up so i think that's safe with that.

Thanks again.

Killian

2.3.2.4  Raw  and  packaging  materials  and  ingredients  shall  be  validated  to  ensure  product  safety  is  not compromised and the material is fit for its intended purpose.  Verification of raw materials and ingredients shall include certificates of conformance, or certificate of analysis, or sampling and testing.
2.3.2.5  Verification of packaging materials shall include:
i.        Certification that all packaging that comes into direct contact with food meets either regulatory acceptance or approval criteria.  Documentation shall either be in the form of a declaration of continued guarantee of compliance, a certificate of conformance, or a certificate from the applicable regulatory agency.
ii.        In  the  absence  of  a  certificate  of  conformance, certificate  of  analysis,  or letter  of  guarantee,  tests  and analyses to confirm the absence of potential chemical migration from the packaging to the food contents shall be conducted and records maintained.

Logic for baking as not a CCP seems slightly bizarre.

What's an LOCG?

:dunno:

Hi Charles,

Our food safety consultant has recommended not to operate as a CCP but certainly as a control point. we monitor and record these temperatures per batch anyway.  

My logic is derived from the "is this step specifically designed to reduce or eliminate" question (if you use that tree) in which case you could argue for baking that it's not and it's more around flavour / quality then you could argue if the controls failed the hazard would not exist because the bread would be rejected.

What would be your logic arguing the opposite?  

Thanks,

Killian

Simon,

LOCG - Letter of Continuing Guarantee

Killian,

I have seen these work, and currently have them in effect for much of the product that we have incoming.  You mention that the companies that you are receiving product from are GFSI audited.  Keep their audit grades on file along with their LOCG and you will be in good shape.  Make sure that you do either plant inspections for the companies or random interval shipment inspections to ensure compliance.

Cheers!

Thanks Brendan. :cool:

Hi Charles,

 

Our food safety consultant has recommended not to operate as a CCP but certainly as a control point. we monitor and record these temperatures per batch anyway.  

 

My logic is derived from the "is this step specifically designed to reduce or eliminate" question (if you use that tree) in which case you could argue for baking that it's not and it's more around flavour / quality then you could argue if the controls failed the hazard would not exist because the bread would be rejected.

 

What would be your logic arguing the opposite?  

 

Thanks,

 

Killian

Hi Killian,

Can browse through this (one of many) discussion -

https://www.ifsqn.co...ccp-validation/

I do think the use of a (micro) Baking-CCP conforms to the literal Codex definition of a CCP.

PS - this rather ingenious Kraft SOP offers either CCP or PRP depending on the Process settings.-

baking CCP-PRP.pdf   484.66KB   214 downloads

Thanks a million guys, much appreciated.

Killian