7 replies to this topic

[Microbiologist Scientist]

Is a Letter of Guarantee from the material supplier (food grade materials) a Control Mesure for the HACCP Plan???????

[Microbiologist Scientist]

I took the SQF implementation System certification and passed it. Now I will take the HACCP certification and then the PCQI.

Thank you all for your advice and your great help.

 

P.D.

I have to pay for certifications when it should be my boss.

But it's okay, I need them anyway.

[Simon]

Thanks for the information Carmelo. 

Is this related to your above question or a general update?

 

Regards,
Simon

[Ivan Ivanov]

Hello,

 

Its depend of what you mean with "food grade matterials". For Europe if this matterials are from plastic its not enough only garantee letter. Your supplier should ensure you and results from migration test.

Its depend and for what you used them. And for which standard you are certified. Its depend and how much details content this letter or this is general letter (e.g. our products confirm with all requirements). 

Again based on your hazard analysis and how you are evaluated this risk. If you are evaluated the risk as a low - it is enough. But if you are valuated as a high - you should thing how to verify this information.

 

Best regards,

Ivan 

[Scampi]

Carmelo----you give those receipts to the accounting manager and tell them you need reimbursed..........this is NOT ok......they NEED you to manufacture as per FSMA.........it is not your responsibility to pay for this.....they don't have someone trained......THEY get put on notice. Period.

 

The letter of guarantee is part of the PCP ......it is ONE portion of your approved supplier plan.....but you could get an LOG from anywhere....you need to show this vendor has been chosen due to : their pest control, allergen control, HACCP plan etc.

[Microbiologist Scientist]

Hi Simon,
I's a general update.

[Antores]

I would say NO for HACCP, yes for HARPC.

 

 

HACCP:

 

The Control Points on a HACCP plan are meant for operational processes.  The letter of guarantee (LoG) is more a pre-requisite for your suppliers, and not a control itself. With that said, you should reference the use of LoG in your HACCP plan when you are doing your risk analysis and use it as justification to determine the hazard for that step (I assume raw materials receiving, or chemical receiving). If you determine the LoG is sufficient to lower the risk to an acceptable level, then you can determine  there is no operational control needed (Not in the HACCP plan), but if it is not sufficient, then you need to implement an actual Control Point (something that is actually done at receiving), such as temperature check, QA inspection, microbiological tests.. etc.   

 

 

HARPC:

 

Different than HACCP, HARPC includes risks and controls not only on operational processes but also on other activities such as supplier control. In this case, a LoG could be a control point, or more like part of a control point program (Supplier approval program). Just be aware that under FSMA, you are responsible to verify your supplier are in compliance with the FSMA regulations, and in the case of food suppliers (ingredients), FDA won’t accept just a LoG by itself as proof that your suppliers are in compliance. 

 

In this case (food suppliers) the LoG is part of the supplier approval program, along with other documents such as supplier risk assessment, 3^rd party audits, internal audits, etc), Based on that, the supplier gets approved or rejected. Then, the actual control point is that the supplier is approved. (e.g. in the company system, or in the list of approval supplier).

Edited by Antores, 22 January 2019 - 02:02 PM.

[MsMars]

I would say no either way (HACCP or HARPC).  The letters should be part of your approved supplier program.  For HACCP, as Antores stated above, your controls are more process-oriented and the letters are part of your approved supplier prerequisite program. For your FSMA (HARPC) program, if you have identified a hazard that needs a supply chain control, you need proof that they are controlling the hazard (a copy of the procedure or program they use to control the hazard, a COA, your own micro testing, etc.) and letters of guarantee likely aren't going to satisfy the FDA.  I've heard from others that FDA will not accept letters of guarantee as proof of supply chain control - they want concrete proof that the supplier is controlling the hazard.