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2.4.4.7 Supplier Approval for "sister" facilities

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Marc Prevost

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Posted 28 November 2018 - 02:29 PM

Hello,

  I work for a produce company that has multiple growing sites, packing sites, and some combined growing/'packing sites.  Often there is transfer of product from one facility to another. The SQF code reads as follows:

 

 

2.4.4.7 Raw materials, ingredients, and packaging materials received from other facilities under the same corporate ownership, shall be subject to the same specification requirements (refer to 2.3.2) and approved supplier requirements as all other material providers.

 

  The way our program is written it doesn't currently differentiate between a supplier from a separate company vs. an "internal" supplier within our own company (product supplied to packaging from a separate growing facility for example).  Our program requirements include having audit certificates provided, food safety contact information, signed specifications, a Letter of Guarantee, and a completed Food Safety Questionnaire. 

  As we are all one company and we do have access to each location's Food Safety programs, certificates, and specifications.  Is it necessary for "sister" locations to complete a questionnaire as the program is currently written?  To me the intent of 2.4.4.7 is to ensure that "sister" sites are all following a food safety program.  I don't see the value in completing a Questionnaire for each site to provide each other site, when this information is readily available but perhaps not in the Questionnaire format. 

  Perhaps I am answering my own question, but would I just revise the Supplier Approval program to differentiate internal suppliers from external ones and not have completing a questionnaire as a requirement for internal suppliers so long as the equivalent information is available to the QA Manager and/or SQF Auditor?   

 

Any advice on different approaches to satisfy this requirement of the code would be greatly appreciated.

 

Thanks in advance for your responses.

 

 



Lesley.Roberts

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Posted 28 November 2018 - 02:54 PM

Hello,

  I work for a produce company that has multiple growing sites, packing sites, and some combined growing/'packing sites.  Often there is transfer of product from one facility to another. The SQF code reads as follows:

 

 

2.4.4.7 Raw materials, ingredients, and packaging materials received from other facilities under the same corporate ownership, shall be subject to the same specification requirements (refer to 2.3.2) and approved supplier requirements as all other material providers.

 

  The way our program is written it doesn't currently differentiate between a supplier from a separate company vs. an "internal" supplier within our own company (product supplied to packaging from a separate growing facility for example).  Our program requirements include having audit certificates provided, food safety contact information, signed specifications, a Letter of Guarantee, and a completed Food Safety Questionnaire. 

  As we are all one company and we do have access to each location's Food Safety programs, certificates, and specifications.  Is it necessary for "sister" locations to complete a questionnaire as the program is currently written?  To me the intent of 2.4.4.7 is to ensure that "sister" sites are all following a food safety program.  I don't see the value in completing a Questionnaire for each site to provide each other site, when this information is readily available but perhaps not in the Questionnaire format. 

  Perhaps I am answering my own question, but would I just revise the Supplier Approval program to differentiate internal suppliers from external ones and not have completing a questionnaire as a requirement for internal suppliers so long as the equivalent information is available to the QA Manager and/or SQF Auditor?   

 

Any advice on different approaches to satisfy this requirement of the code would be greatly appreciated.

 

Thanks in advance for your responses.

 

 

 

 

Hi there - I think you have answered your own question?....

 

I'm currently working through BRC 3.5 - supplier monitoring & approval which makes reference to supplier's accreditation.

 

For me there's nothing that drives me crazy like a small company sending an 80 page questionnaire which asks:

 

1. Do you have accreditation (SQF/BRC/ISO22000)

2. Do you have HACCP?    ....................       well of course, it's part of the standard!

3. Do you approve your suppliers............      well again yes, part of the standard

4. Do you have preventive maintenance....    again, part of the standard....

 

and so on until you're losing the will to live - and actually I just cross these sections through now & write "see question 1." as there's no point in completing documentation for it's own sake!!.

 

 

 

I believe that as long as you have the sister site's audit report & confirmation that they will advise you if the certification is lost this should be enough. 

You could also quote group quality role (if there is one) to say that this function assesses the site's monthly performance & is responsible for ensuring food safety across group and would advise receiving site in the event of any known risk?



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Marc Prevost

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Posted 29 November 2018 - 02:52 PM

Thank you Lesley for your reply.  We're on the same page with regard to questionnaires. I have the" joy" of completing these for our company.  The whole point of having and international standard is to have all those questions covered by your 3rd party GFSI audit.  I like your approach of just crossing these questions out.  I'm going to steal that. 

 

Thanks

Marc 



Lesley.Roberts

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Posted 29 November 2018 - 03:14 PM

Hi Marc

 

No problem - unfortunately technical "administrators" may not actually understand what they are trying to achieve when they send SAQs & can get quite annoyed when you cross through the sections on these type of documents.  If/when that happens I usually ask to speak with the site TM/QM & respectfully suggest that their documentation might benefit from a revision?..

 

In recent months we have actually gone a step further - for the smallest customers (who are the ones who usually lack the understanding of why SAQs are being submitted & have poorest formats) we have decided that they will receive an information "pack" (BRC/kosher/halal cert/HACCP plan/site details & relevant specs etc.) but we no longer complete reams & reams of documentation for them - we are not clerks or administrators - we are technical/quality professionals.  Larger & more profitable customers still receive the same service as they ones generating most revenue.

 

This step was agreed 100% with sales staff & was needed because I believe our site quality & technical managers should be concentrating their teams resources on the BRC 7 - 8 transition, not completing obsolete paperwork as this activity add no value to our company, and little to the customers.

 

So far no opposition, quality staff happier & BRC transition is on schedule.





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