COA`s requirement

I am writing a SOP and tightening our approved supplier program. We are a cookie manufacturer and we request COA`s. We do not always receive them and they all have different testing standards.

My questions:

1)How do I determine my high risk(Biological) Ingredients. History? Recalls?

These ingredients are what I am currently thinking of higher risk in cookie type products.

-Eggs

-Flours

-Spices

-Margarine
-Peanut Butter

2)What is a website for reference?

3)What if they do not test for known pathogens?

4)I have had customers ask us to validate ingredients thru testing. But the lab has also told be it is not in my best interest, because if there is a glitch it could cause a law suit or other. Suggestions?

I would appreciate any imputs. Thanks You!

Dear C. Smith,

You can agree with your suppliers, that they send you a COA with every delivery. The verification of its presence and its conformity will be part of the incoming goods control. You can start demanding them and gradually adapt them when you are building your knowledge base.

1. High risk. Please, don't forget to have your own process in mind when doing this exercise. For each raw material or group, you determine the Hazards (Microbiological, Physical, Chemical, Allergen, Food fraud/Adulteration) and the occurrence (Frequency) of these hazards. If you do it together with other people, you'll be surprised of how far you can come. You will see, that there will be different risk categories in your raw materials.
   To refine the so called risk assessment, you can have a look in the history of recalls. There are also databases around here (question 2), which mention all the possible hazards for each raw material. All depends on the context and your objectives.
2. See above.
3. There may be reasons, why they don't test for pathogens. For example, when there are no possibilities for growth or survival. As mentioned under point 1, you will have a clearer picture once your risk assessment is finished.
4. Analysis results can be used to confirm certain statements, thus be helpful during the validation of your risk assessment.

Summarizing, the process of demanding COA's can be started already (together with the purchasing department) and you'll need to do the work of the risk assessment.

Kind regards,

Gerard Heerkens

As far as ensuring your COA's are sent, I tell every supplier that the invoice for said product will not be paid until I have all COAs associated with that invoice. I keep the COAs with the delivery ticket/BOL. I don't file the the delivery ticket/BOL until the invoice is sent to payables. This really helps me keep my COAs in order. When I have a supplier that is wondering why they haven't been paid, I'll dig through my unfiled BOLs and see that they haven't sent the COA. After starting this policy, I typically always have a COA in my email before the product hits my dock as they want to get paid ASAP.