BRC V8 - 9.3 Traded Products Product Inspection and Lab Testing

Good afternoon - 

I'm struggling with section 9 of BRC version 8. We repackage liquid sweeteners, then we also warehouse many other items as an ingredient distributor, so while the repacking/manufacturing is covered by HACCP and the other clauses, I'm assuming the distribution items would fall under section 9. We do not alter or repack these products at all, only resell. We do have a supplier approval program for these suppliers. 

My question is, in 9.3 it talks about product testing to ensure it's meeting the specifications/COAs, but why would we open the products to test them if we arent the ones using it? I can understand from the "performance monitoring" perspective, but I've been tracking their performance by customer complaints, and if the supplier keeps sending out of spec product, wouldnt it show up there?

Am I interpreting this clause correctly?

Thanks

I guess a better question would be, what is the difference between "traded products" in BRC Food Safety section 9 and Wholesale branded products in BRC Storage and Distribution section 9?

9.3 is understandably similar, although not identical, to section 4.4 of the Agents & Brokers standard.

We have Traded Goods excluded from our BRC Food scope as we maintain separate certification under Agents & Brokers, but the broad intent seems to be the same - there are slight difference perhaps due to the expectation that most Agents won't have access to their own testing facilities.

Nonetheless I'd take the same approach for both, and make use of the provisions of clause 9.3.2.

You can rely on the analysis provided by your suppliers, subject to you being able to justify this position - presumably you'll have e.g. supplier assessment records with detail showing that the analytical methods they use are appropriate, the people doing the testing are competent, everything is calibrated etc. Combined with your tracking of complaints/issues this should suffice, but the expectation is that you'd be addressing this more proactively than simply waiting for your customers to tell you if there is an issue - broadly, you should know, or at least have reasonably significant confidence, that the product is right before you supply it onwards.

Do you use any of these traded items in your own production?

If so, you can perhaps come up with a position whereby you don't routinely sample every batch, but the bulk of your monitoring to ensure that suppliers' analysis is correct / products are in spec can be from your own QC testing prior to using the products.

The standard does state "independent product analysis" under 9.3.2, so this may come down to auditor interpretation - for Agents & Brokers we've found that the expectation is that the analysis is independent of the manufacturer, but equally this could be viewed the other way and be an expectation of genuinely third-party testing. The Interpretation Guide doesn't actually clarify this point though.

Otherwise you may need to come up with some sort of schedule to sample a proportion of the traded goods, and obviously as it's BRC you'll need to determine this by risk assessment...

I see what you're saying, and I appreciate the response. To give you some more background, the storage and distribution part of the warehouse is completely separate area and none of those items are used in production. Under the Storage and Distribution guidelines, we would be considered a wholesaler of products that aren't our brand, and those requirements for supplier approval are MUCH slimmer than what I'm looking at in the Food Safety guidelines. I'm starting to think we should just get two separate certifications, because S&D lines up much better with what we do on that side of the business. 

We run two BRC standards and really can appreciate that this can be an effective way of matching certification requirements to the actual nature of operations/activities, so possibly one to discuss with your certification body to see if your expectation on scope/applicability fits what they think they can actually audit.
Also bear in mind that it will almost certainly double the cost - unless you're lucky and your CB genuinely has sufficient auditors who can cover both standards with the right categories (they may tell you that they do, but that's not quite the same as actually being able to do it in practice) then you'll like end up having two separate annual audits with two sets of fees.