SQF Edition 8 Quality System Element 2.4.4.3 - COA Required
SQF Edition 8 states:
2.4.4.3 Material suppliers shall only be accepted into the facility based on either certificates of analysis for every lot
received, or inspection at receipt to ensure materials comply with specification.
I work for a company that makes food contact packaging. I believe the requirement for a COA is new to Edition 8.
We received a nonconformance for the supplier COA's not matching what we had listed in our internal specs (min/max/target were not the same). I am not the FSP but I am on the team to correct this nonconformance.
I am looking for feedback from other people:
1. Do you receive a COA from every material supplier?
2. Are you doing any inspection (testing) instead of receiving a COA?
3. Any problems getting COA's from suppliers that previously didn't provide them?
4. Why was requiring a COA from every supplier added to Edition 8?
5. Have any auditors accepted a COC or Letter of Continuing Guarantee instead of a COA?
Just to clarify, are you certified to both the Quality Code and the Manufacture of Food Packaging Code?
Yes, certified to both. I have been told that you can be just SQF Food Safety certified, or both SQF Food Safety and Quality certified, but you cannot be only SQF Quality certified.
I am also unclear on this one.
2.4.4.1 lists out various types of materials - "raw materials, ingredients, packaging materials and services" - but in 2.4.4.3 it simply states "Material suppliers."
Does this mean we need a CoA, CoC for packaging materials or else we need to inspect?
What does the code mean by "raw materials?"
Confusing!
I am looking for feedback from other people:
1. Do you receive a COA from every material supplier?
No, we do not require COA for every supplier, we conducted risk assessment of all our raw material, packing material and based on the risk assessment, our suppliers are not high risk suppliers to require every COA during receipt. No auditor have questioned this.
2. Are you doing any inspection (testing) instead of receiving a COA?
However, on all our receiving, QA must be present to inspect the product.
3. Any problems getting COA's from suppliers that previously didn't provide them?
Suppliers are notorious with not providing COA especially if you're not directly sourcing from the actual manufacturer (i.e. broker, 3rd party seller etc.). However, some suppliers still provide COA's despite us not requiring them. We review it, sign off on it and keep it on file if we received one.
4. Why was requiring a COA from every supplier added to Edition 8? In 2.4.4.3 there was no mention of requiring COA, where did you get this, standard states "The responsibility and procedure for selecting, evaluating, approving and monitoring an approved supplier shall be documented and implemented"
5. Have any auditors accepted a COC or Letter of Continuing Guarantee instead of a COA?
From your risk assessment, if this is your plan of action to mitigate the risk in your materials and you have evidence that your suppliers have been informed of it and agreed to your requirements, I don't think an auditor will have issues with this if done properly. We require letter of guarantee renewed every year for medium risk suppliers. For all others, supplier approval program is carried out every 3 years or unless if there is major changes which the supplier is required to inform us and provide us documentations.
I am also unclear on this one.
2.4.4.1 lists out various types of materials - "raw materials, ingredients, packaging materials and services" - but in 2.4.4.3 it simply states "Material suppliers."
Does this mean we need a CoA, CoC for packaging materials or else we need to inspect?
What does the code mean by "raw materials?"
Confusing!
IIRC, this semantical comment has been discussed previously. You might try a little searching.