12 replies to this topic

[QAGB]

Hi all,

 

What are your policies regarding "customer requirements" imposed upon your facility that are not regulatory based? For example, "customer X requires your company to conduct GMP audits 5x per day". This is not something that has happened, but just an example as to what I mean. 

 

Obviously, we want to meet an exceed regulatory standards for the FDA, state level requirements, and for GFSI. We are often times willing to accept customer requirements where we can and customer can provide justification for needs. However, as maufacturers, most of us already have our hands full with regulatory requirements, and these expectations should satisfy customers. What do you do when they don't?

 

How about customers of customers? Do you allow your customer's customers to come in and audit your facility? Do you allow them to impose special requirements on your facility?

[Scampi]

I don't like anyone entering the facility when it can be avoided

 

Politely offer your audit results/summary 

 

Wouldn't let a customers customer come in..........for all I know they are looking to make my product themselves and are using access as research

 

 

BUT $$$$$$$$ talks................so really depends on how much revenue said customers are responsible for at your particular facility.

[QAGB]

I don't like anyone entering the facility when it can be avoided

 

Politely offer your audit results/summary 

 

Wouldn't let a customers customer come in..........for all I know they are looking to make my product themselves and are using access as research

 

 

BUT $$$$$$$$ talks................so really depends on how much revenue said customers are responsible for at your particular facility.

 

Hi Scampi,

 

I agree; I'm not crazy about people coming into the facility for a number of reasons. I don't like customers getting a chance to see other customers products on our lines, and for auditors to attempt to review records that may pertain to other customers as well. I'm also not crazy about having to be pulled away from daily duties for audits (especially since we GFSI certified...but that's a topic for another time).

 

Here's the deal though; the customer generates a lot of revenue, but I really don't know about the customer's customer in relation to how much of the product they sell to them. It is a private label, and we really only handle the product until shipping to their distribution centers.

 

One thing I've noticed is the more "corporate" the organization (forgive me folks - for those of you that work for the larger companies), the more they feel they can impose their own standards upon a facility. Meanwhile, conversely, many of the corporate organizations don't allow 2nd party audits by their own customers (go figure).

 

Our company has a pretty generous allowance to customers. I believe we've only discouraged a customer from coming into our facility once. Even then, it wasn't a definite no. I feel it is generally expected that we take on any audit if requested based on what I've seen. With that being said, it doesn't make me happy, but I deal with it. My problem comes when customers bring in their own expectations manuals and requirements, which really have nothing to do with regulations -- just things they want (require) us to do. 

 

If you're in a position where it would be frowned upon to disallow a customer's customer to come in to your facility, but they bring extra requirements they want you to add to your programs, what would you do?

[Scampi]

Most of the time those folks are asking for things without understanding the "hazards" are already covered in the facility plan. I would politely ask them what the end goal is....................and then politely explain to them how you already mange those things.....worth a shot QAGB

 

The problem is no one is pushing back...............ever......................and thus the situation your now in

[SQFconsultant]

Several (actually it is a growing number) of our clients have built-in customer requirements into the sales process, they each worked up a sheet basically explaining the GFSI (in all cases, SQF) scheme under which they are certified, the requirements, etc of the standards and that they would be happy to provide their direct customer with a full copy of their most recent SQF Audit and corrective actions as they apply.  

 

In addition the sales reps gather whatever additional requirements the customer may have and transmit that infomation back to the QA department, as QA may want to discuss with the soon to be new customer.  There are restrictions by our clients as to what they are willing to do and what they won't do.  If the customer wants a qualified auditor (one from a CB for instance) to audit the facility each client is ok with that requirement, as long as the customer pays for the audit, all expenses involved and provides our clients with monetary reimbursement for escort labor.

 

It's working out pretty well - and it sure does clear the air real fast.

 

We had one client years ago that had a new customer and the customer demand was that each container of their apple sauce was required to go thru a metal detector - sounds fairly easy for most companies, since most use metal detectors. There was only one issue that QA mentioned to the customer... the apple sauce container is a metal can.

 

Oh yeah, that was an interesting - they kept on demanding this and then finally gave in because our client was doing in-line detection already, but even that was hard to get the customer to understand becuase the customer was a big corporation, big customer, lots of money - and the customer heard that all companies must have metal detectors.

 

Even as a consultant, I feel your pain.

[zanorias]

most of us already have our hands full with regulatory requirements, and these expectations should satisfy customers. What do you do when they don't?

 

 

This seems to be becoming the case more and more. We've just had our first audit from a new retail customer, we already have BRC AA but the extra requirements and recommendations they've made would realistically need us to hire more Technical staff just to spend the admin time to comply.

 

Generally with customer requirements, this comes down to a financial decision - is the extra expenditure to do whatever it is the customer is asking worth the business of the customer? Last year we stopped selling to a customer who didn't take much but had many OTT requirements i.e. calibrating temperature probes twice a day.

[pHruit]

Similar to the other posts, we'd generally consider each request based on time/money commitment required from us, vs. value of the customer to our business.

Those requesting particularly pedantic/outlandish things are usually told that this is not presently in place, but that any specific requirements they may have will need to be included in commercial contracts. This provides a mechanism for us to assess the cost and to pass it back on to them - we'll simply increase the price by the cost divided across the volume of product, plus a bit for the faff, and 9 times out of 10 we find that once they appreciate the extra money involved they actually don't need the unusual/excessive thing they were asking for...

Sometimes we'll also insist on a much higher MOQ - if you want bespoke process etc then you need to buy a whole batch, so you may have to commit to 10000kg rather than 25kg once ever so often. Again it's quite effective.

 

I do think there is some merit to having some customers audit, as they bring a range of new perspectives and this can genuinely generate ideas for improvements that you may not have thought of. But again, there is a sensible balance that needs to be struck in terms of time/cost - if there is no sensible business case then we'll just reiterate that we're certified to two BRC standards at AA grade, and have shared the certs and reports.

 

We will occasionally allow customers' customers to audit us, but again only where there is genuine significant commercial value to the business, either directly to us or to other companies in our group. We've turned away most such requests. Many of our clients try to include a provision in their Ts&Cs for open and free access to our site for both them and their customers (amongst other outlandish things - starting to see this extended to include access to our suppliers' sites too!) - always read the Ts&Cs and challenge where they're unreasonable

[Andy_Yellows]

Tell you what I can't bear- getting through certification/local authority with minimal fuss before being met with a 'I personally would prefer.........' from a customer auditor who has just done a level 2 in food safety and thinks they've got it sewn up. Our customers often send people with a year or two of experience in food, while usually also being in charge of health and safety, and has a certificate in auditing skills which therefore makes them the designated supplier auditor. We've worked a long time to develop an in-depth and ever-evolving food safety system and I find it very hard to dismiss their ideas politely.

 

Anybody have any recommendations on how to deal with these people?

[QAGB]

Several (actually it is a growing number) of our clients have built-in customer requirements into the sales process, they each worked up a sheet basically explaining the GFSI (in all cases, SQF) scheme under which they are certified, the requirements, etc of the standards and that they would be happy to provide their direct customer with a full copy of their most recent SQF Audit and corrective actions as they apply.  

 

In addition the sales reps gather whatever additional requirements the customer may have and transmit that infomation back to the QA department, as QA may want to discuss with the soon to be new customer.  There are restrictions by our clients as to what they are willing to do and what they won't do.  If the customer wants a qualified auditor (one from a CB for instance) to audit the facility each client is ok with that requirement, as long as the customer pays for the audit, all expenses involved and provides our clients with monetary reimbursement for escort labor.

 

It's working out pretty well - and it sure does clear the air real fast.

 

We had one client years ago that had a new customer and the customer demand was that each container of their apple sauce was required to go thru a metal detector - sounds fairly easy for most companies, since most use metal detectors. There was only one issue that QA mentioned to the customer... the apple sauce container is a metal can.

 

Oh yeah, that was an interesting - they kept on demanding this and then finally gave in because our client was doing in-line detection already, but even that was hard to get the customer to understand becuase the customer was a big corporation, big customer, lots of money - and the customer heard that all companies must have metal detectors.

 

Even as a consultant, I feel your pain.

 

 

Thanks SQFconsultant.

 

We do try to ask for requirements upfront from our own customers. I'm generally ok with our customers' requirements. Every now and then, we will have an over the top requirement, but most of the time we attempt to charge customers for things that we either can't do in house, or will require additional needs on our end. I'm ok with our customers conducting audits too. I'm not crazy about people being on site, but I can understand why a customer would need and want to visit a facility to understand their process. For that reason, we will allow our customers to come in and conduct audits.

 

My problem isn't really with our customers. My problem is with our customer's customers. We do a lot of private labeling (co-packing if you will), and so these customers send the products to other customers, who in turn, feel they need to come in. When they come in, they aren't just asking if we have a filter or metal detector, they want to tell us that we have to have a certain type of metal detector or we must check 80 times a day per "their requirements". We didn't sign any such contract with our customer's customer, so why are we abiding by someone else's requirements that aren't our customer?

 

I totally relate to the apple sauce in the metal can story, because that is along the lines of the situations we deal with from our customer's customers. They don't understand the big picture and the justifications behind the processes, all they understand is that they have their own requirement for a metal detector and that everyone has to play by those rules; even when they don't make sense.

[QAGB]

Similar to the other posts, we'd generally consider each request based on time/money commitment required from us, vs. value of the customer to our business.

Those requesting particularly pedantic/outlandish things are usually told that this is not presently in place, but that any specific requirements they may have will need to be included in commercial contracts. This provides a mechanism for us to assess the cost and to pass it back on to them - we'll simply increase the price by the cost divided across the volume of product, plus a bit for the faff, and 9 times out of 10 we find that once they appreciate the extra money involved they actually don't need the unusual/excessive thing they were asking for...

Sometimes we'll also insist on a much higher MOQ - if you want bespoke process etc then you need to buy a whole batch, so you may have to commit to 10000kg rather than 25kg once ever so often. Again it's quite effective.

 

I do think there is some merit to having some customers audit, as they bring a range of new perspectives and this can genuinely generate ideas for improvements that you may not have thought of. But again, there is a sensible balance that needs to be struck in terms of time/cost - if there is no sensible business case then we'll just reiterate that we're certified to two BRC standards at AA grade, and have shared the certs and reports.

 

We will occasionally allow customers' customers to audit us, but again only where there is genuine significant commercial value to the business, either directly to us or to other companies in our group. We've turned away most such requests. Many of our clients try to include a provision in their Ts&Cs for open and free access to our site for both them and their customers (amongst other outlandish things - starting to see this extended to include access to our suppliers' sites too!) - always read the Ts&Cs and challenge where they're unreasonable

 

Thanks pHruit.

 

I agree, there is merit to having customer audits. I've never turned away a customer, because they directly buy from us, and should understand the process by which their products are made. As you said, they also can give insights and different perspectives to your programs (and I like that). The only requirements I now have with our customers is that they are only allowed to visit the parts of the facility where their products are made. We have had a couple auditors in the past walk through our whole plant, visiting lines that have nothing to do with their products. At this point, if the product has a chance of being made in that area, we will visit and they can inspect. At most, I might show the auditor where our other parts of the facility are, just so they are aware and can follow product/personnel flow better. Otherwise, they are not allowed to be in those areas for inspection.

 

Wow, I have yet to see any terms and conditions that involve allowing people to have access to our suppliers. We can't even get access to some of our suppliers.    That would definitely require a challenge.

[QAGB]

Tell you what I can't bear- getting through certification/local authority with minimal fuss before being met with a 'I personally would prefer.........' from a customer auditor who has just done a level 2 in food safety and thinks they've got it sewn up. Our customers often send people with a year or two of experience in food, while usually also being in charge of health and safety, and has a certificate in auditing skills which therefore makes them the designated supplier auditor. We've worked a long time to develop an in-depth and ever-evolving food safety system and I find it very hard to dismiss their ideas politely.

 

Anybody have any recommendations on how to deal with these people?

 

Hi Andy_Yellows,

 

We have those too. Usually when we challenge their ideas, they become testy. If they do try to make something a finding that isn't based on regulation and is more of the "I would personally prefer" type response, I will submit justification in the corrective action report, and state why the finding is not valid. I've not had one come back from a customer stating the answer wasn't good enough.

 

I'm just struggling with the customer's customer, because more times than not, they are a large corporate base, where they feel what they say is final. If you don't comply then they'll move on (even if the volumes aren't high). Then you risk issues with your customer relations as well. As Scampi said earlier, there aren't enough people pushing back. I push back where I can, but I don't exactly know where to draw the line.

[pHruit]

Wow, I have yet to see any terms and conditions that involve allowing people to have access to our suppliers. We can't even get access to some of our suppliers.    That would definitely require a challenge.

  

We're actually seeing it fairly regularly, across a growing number of customers...

It seems to have snuck in under the guise of the "supply chain transparency" that is currently British retailers' favourite topic - if you say yes, you can't possibly follow it up as none of our suppliers want our customers turning up unannounced, and if you say no then the customer infers that you've got something to hide in the supply chain, and thus by implication are almost certainly using slave labour to make adulterated products. If it's happening here then you may see it start appearing elsewhere, as it so often feels like the big brands and retailers are permanently looking for daft ideas to borrow from each other

 

 

Hi Andy_Yellows,

 

We have those too. Usually when we challenge their ideas, they become testy. If they do try to make something a finding that isn't based on regulation and is more of the "I would personally prefer" type response, I will submit justification in the corrective action report, and state why the finding is not valid. I've not had one come back from a customer stating the answer wasn't good enough.

 

I'm just struggling with the customer's customer, because more times than not, they are a large corporate base, where they feel what they say is final. If you don't comply then they'll move on (even if the volumes aren't high). Then you risk issues with your customer relations as well. As Scampi said earlier, there aren't enough people pushing back. I push back where I can, but I don't exactly know where to draw the line.

Get your commercial colleagues involved - work out roughly what it'll cost your business to implement whatever it is that's been requested, add a healthy extra chunk for it generally being a PITA, and offer them the choice via your sales team. This can get your direct customer on your side, as they aren't likely to want to pay a higher price and will often struggle to be able to pass on the same increase to their customer. If nothing else, the potential for a higher price can sometimes cause other people at the customer / customer's customer to become involved, and this can lead to an outbreak of common sense. Not always, but occasionally at least

 

Also be aware that if you're supplying ingredients to the big corporates, many of them will have gone through a long product development/ingredient approval process, and this will make them disinclined to change supply routes unless there is an actual genuine problem. One auditor saying "we'll need to look elsewhere" can be a useful lever to try to get you to jump through the hoops, but if you push back you will sometimes find that the overall considered corporate position is actually somewhat different because the non-compliance isn't actually on anything significant, and they don't want to go through all of the trials, benchmarking, focus groups etc to get an ingredient change approved.

I've sometimes found that saying "no" will lead to being passed up the chain of command, until eventually you have the discussion with someone who genuinely has sufficient seniority to make a call on it, and 90+% of the time the reason they have the seniority is that they have the experience and intellect to see what does/doesn't actually make sense, so they can agree with you. Or at least if they still disagree, they may even provide a legitimate basis for the request. Either is fine, I guess.

 

Should we have a separate "off topic" thread for light-hearted discussion of our favourite ridiculous non-conformances that IFSQN members have received over the years?

[QAGB]

We're actually seeing it fairly regularly, across a growing number of customers...

It seems to have snuck in under the guise of the "supply chain transparency" that is currently British retailers' favourite topic - if you say yes, you can't possibly follow it up as none of our suppliers want our customers turning up unannounced, and if you say no then the customer infers that you've got something to hide in the supply chain, and thus by implication are almost certainly using slave labour to make adulterated products. If it's happening here then you may see it start appearing elsewhere, as it so often feels like the big brands and retailers are permanently looking for daft ideas to borrow from each other

 

 

Get your commercial colleagues involved - work out roughly what it'll cost your business to implement whatever it is that's been requested, add a healthy extra chunk for it generally being a PITA, and offer them the choice via your sales team. This can get your direct customer on your side, as they aren't likely to want to pay a higher price and will often struggle to be able to pass on the same increase to their customer. If nothing else, the potential for a higher price can sometimes cause other people at the customer / customer's customer to become involved, and this can lead to an outbreak of common sense. Not always, but occasionally at least

 

Also be aware that if you're supplying ingredients to the big corporates, many of them will have gone through a long product development/ingredient approval process, and this will make them disinclined to change supply routes unless there is an actual genuine problem. One auditor saying "we'll need to look elsewhere" can be a useful lever to try to get you to jump through the hoops, but if you push back you will sometimes find that the overall considered corporate position is actually somewhat different because the non-compliance isn't actually on anything significant, and they don't want to go through all of the trials, benchmarking, focus groups etc to get an ingredient change approved.

I've sometimes found that saying "no" will lead to being passed up the chain of command, until eventually you have the discussion with someone who genuinely has sufficient seniority to make a call on it, and 90+% of the time the reason they have the seniority is that they have the experience and intellect to see what does/doesn't actually make sense, so they can agree with you. Or at least if they still disagree, they may even provide a legitimate basis for the request. Either is fine, I guess.

 

Should we have a separate "off topic" thread for light-hearted discussion of our favourite ridiculous non-conformances that IFSQN members have received over the years?

 

 

That's a good point. I learned some time ago that I really have to read the terms and conditions very carefully, and when I don't agree with something or find an issue, I will forward to senior management. I'm going to have to keep a really keen eye out on documents like those.

 

Thank you for the further discussion too on pushing back on the requirements. This is good advice. I want to maintain customer relations, but at the end of the day, we still have a business to run. If we managed everyone's expectations aside from the ones we already have, we'd never get anything done.

 

There is a thread for discussing non-conformances though; it is here. https://www.ifsqn.co...on-conformities