18 replies to this topic

[Ieatcookies]

Hello all, 

 

I have a small query and wondered if anyone faced similar situation before. 

 

I am currently working with the small manufacturer to gain their BRC certification. And there is a quaestion to raise. One ingredient is bought in tiny amounts, and no suppliers want to work with Company in question, therefore the Company is buying the ingredient (milk based product) from the retailer. They are using 1.6kg of the ingredient in two weeks. and now the questions:

 

1. how to do the supplier approval, if the product is bought from the retailer? (options are to use only BRC certified supplier, find the BRC cert on their website, but no spec for the product available) and how to maintain the traceability (keep shop receipts and BBE date?)

 

2. the amount of the ingredient is so negligible and milk is not even detected in the final product, is it worth to mention the ingredient (not preferable option).

Edited by Marcistka, 01 September 2019 - 02:00 PM.

[Charles.C]

Hello all, 

 

I have a small query and wondered if anyone faced similar situation before. 

 

I am currently working with the small manufacturer to gain their BRC certification. And there is a quaestion to raise. One ingredient is bought in tiny amounts, and no suppliers want to work with Company in question, therefore the Company is buying the ingredient (milk based product) from the retailer. They are using 1.6kg of the ingredient in two weeks. and now the questions:

 

1. how to do the supplier approval, if the product is bought from the retailer? (options are to use only BRC certified supplier, find the BRC cert on their website, but no spec for the product available) and how to maintain the traceability (keep shop receipts and BBE date?)

 

2. the amount of the ingredient is so negligible and milk is not even detected in the final product, is it worth to mention the ingredient (not preferable option).

 

Hi Marcistka,

 

Similar queries to (1) have been discussed here. Typical conclusions were -

 

 If the supplier cannot be approved, find another supplier.

 

Re (2) - Not sure what you mean by "not detected" but I anticipate you are referring to allergenicity ?. The answer will presumably be dictated by the local Regulatory Labelling Laws.

[FoodSafetyPlanet]

Hi M,

BRC aside, I don’t recommend retail as a primary supplier (for starters, there’s an unpredictable supply). Since it sounds like it’s not a main component, have you looked into reformulating or using a shelf stable alternative? If you’re purchasing a small amount, ask if they’ll agree to a courier service or see if a distribution center carries it.

[pHruit]

1. There should be traceability data on the retail pack, so that the retailer / brand owner can maintain their own traceability requirements. If you can find the BRC cert on their website then that gets you part of the way there on the approval front, but how do you propose to show compliance with 3.6/3.6.1? (Specifications shall exist for raw materials (including primary packaging), finished products and any product or service which could affect the integrity of the finished product)

 

2. If it is allergen labelling about which you're concerned then it is critical to note that there is no threshold at which this takes effect, with the exception of the 10mg/kg limit for SO₂. In any case it's an ingredient (and thus no potential exemption under carryover rules), so IMO this definitely should be declared.

[GMO]

It may be glib to say "use another supplier" but it is probably possible.  There are ingredient wholesale suppliers who get bulk deliveries from the big manufacturers then break them down into smaller amounts for small manufacturers.  If we're talking chilled, I know of some small BRC dairies and some deal through wholesalers.  Perhaps you can share what the ingredient is so we can help?

[Ieatcookies]

Hi,

Thank you all for replies. The ingredient is a kefir. Problem we face is no supplier want to even start working with you and fill in the required documentation for 50kg kefir per year. The company struggles to get supplier. Therefore I Wonder if there is an option to overcome the need of spec @if we find BRC approved company?

[Charles.C]

Hi,

Thank you all for replies. The ingredient is a kefir. Problem we face is no supplier want to even start working with you and fill in the required documentation for 50kg kefir per year. The company struggles to get supplier. Therefore I Wonder if there is an option to overcome the need of spec @if we find BRC approved company?

 

You can have a look at this thread to see some of the potential complications as previously discussed -

 

https://www.ifsqn.co...-approval-3513/

 

(The thread seemed to sort of eventually run out of ideas. )

[pHruit]

Hi,

Thank you all for replies. The ingredient is a kefir. Problem we face is no supplier want to even start working with you and fill in the required documentation for 50kg kefir per year. The company struggles to get supplier. Therefore I Wonder if there is an option to overcome the need of spec @if we find BRC approved company?

The BRC standard seems to be entirely unequivocal about it - specifications shall exist...

If your primary issue with suppliers is getting them to fill out paperwork, perhaps the question is: do you actually need the forms?
If you can find a source that is BRC certified and will provide the certificate (and possibly report), spec, perhaps other standard docs such as allergen policy, process flow diag etc, can you not build a reasonable supplier approval position that way? This would avoid scaring them away with forms (which I can understand - I'd not be that enthusiastic about using my team's time to complete paperwork for 50kg - it will cost more than we'd make from the sale), and should leave you in a far stronger position than buying from a retailer with effectively no information.

[GMO]

Daft idea, make it yourself?  Kefir "grains" (starter culture) is available commercially.  If you're using it as an ingredient (especially if it's cooked) the risk would be low.  If you're using it chilled with no heat treatment, I'd definitely not use supermarket bought stock.  They could have a withdrawal that you never know about or a recall you don't see.

 

The other question is does the kefir really add to the product or would yogurt be a good substitute (with relabeling)?

[pHruit]

Daft idea, make it yourself?  Kefir "grains" (starter culture) is available commercially. 

 

I like the idea, but does this not simply transfer the approval requirement from the kefir supplier to the supplier of the starter culture?
Presumably also requires an additional HACCP plan etc for the manufacturing process for the kefir.

It's a bit of a trendy buzzword at the moment so I could understand a marketing-led reticence to swap it out, but I think your substitution suggestion is pragmatic if they can't find a supplier to provide small quantities of kefir accompanied by basic standard information.

[Ieatcookies]

hi all. yes, the situation is a bit tough and the documentation is not the only problem. Yes, we will not get the supplier to fill the docs in, but we will also not get the suppliers to pack 2kg per week.  We were discussing to be absolutely honest with potential suppliers and tell them what the situation is. request the spec and certifications and still buy from retailer. if anyone has a better idea, please shout do you think this will work?

 

Also, thank you so much for all comments and suggestions.

[pHruit]

In principle that could be a reasonable solution, but you'll need to have a bit of a think about how you'll satisfy the requirements of section 3.5.1 for BRC.

3.5.1.5 should be relatively simple if you can get the information directly from the manufacturer.

3.5.1.2 is possibly a bit more of a challenge, as the retailer will be your "supplier" (in accordance with the definition in the glossary in Appendix 9 of the standard). I'm genuinely not sure how this would be interpreted by an auditor - at face value it could be read as implying that you would need to either audit the retailer (as unlikely to be BRC A&B /GFSI), or if you can justify the low risk route you'd possibly still need to get a questionnaire completed and have them do a trace exercise or similar at first approval and at least every three years.

If no-one else here can shed more light on this then it could be worth asking the question on the BRC Participate forum (please share response here if you do).

[Ieatcookies]

 

If no-one else here can shed more light on this then it could be worth asking the question on the BRC Participate forum (please share response here if you do).

 

 

 

great idea! I will ask on the BRC participate forum.

[GMO]

Why not try googling "small farm yogurt UK" and contacting some farm scale yogurt producers to see if they'd do some for you?

 

So a couple of suggestions from a quick google;

 

https://www.timsdairy.co.uk/

http://www.manorfarmyogurt.co.uk/

https://lancashirefarm.com/

https://www.hurdlebrook.co.uk/

 

Also if could you freeze it?

 

As for the small supply of starter culture, not necessarily a problem.  It's always small for some dairies depending on what they make.  The problem is storage as I'm not sure about Kefir grains but some cheese starters need to be stored at -40oC.  Also I get where you're coming from with HACCP changes.  It would be a big deal if you're using it without heat treatment but less so if it's an ingredient which is later cooked.

[GMO]

I'm being daft and pHrutt is right.  We used to use a product from a supermarket as a processing aid in one factory.  All we did was contact the supplier directly for spec, BRC approval etc and never had an issue.  That was against v7 though.  Not as unstable an ingredient as kefir mind but it may be possible, especially if you also got some kind of agreement they'd contact you in the event of a recall.  As pHrutt points out though effectively the supermarket supply route is now part of your supply chain which is still a risk.

[Charles.C]

I'm being daft and pHrutt is right.  We used to use a product from a supermarket as a processing aid in one factory.  All we did was contact the supplier directly for spec, BRC approval etc and never had an issue.  That was against v7 though.  Not as unstable an ingredient as kefir mind but it may be possible, especially if you also got some kind of agreement they'd contact you in the event of a recall.  As pHrutt points out though effectively the supermarket supply route is now part of your supply chain which is still a risk.

 

Daft ? No Way !

 

have a look at the mazy link in Post 7.

[pHruit]

I'm being daft and pHrutt is right. 

pHruit isn't sure that pHruit is right...

 

It's the sort of thing I could see many auditors easily overlooking, as if they picked out the ingredient as part of review of 3.5.1 then the "supplier" BRC etc is available.
It becomes more tricky if it's part of a trace exercise though, as that then opens the can of worms about what the "supplier" actually is.

Hopefully the OP will get some feedback from BRC on exactly how this is supposed to work.

[QAGB]

pHruit isn't sure that pHruit is right...

 

It's the sort of thing I could see many auditors easily overlooking, as if they picked out the ingredient as part of review of 3.5.1 then the "supplier" BRC etc is available.
It becomes more tricky if it's part of a trace exercise though, as that then opens the can of worms about what the "supplier" actually is.

Hopefully the OP will get some feedback from BRC on exactly how this is supposed to work.

 

I'd like to know this as well. Getting documents sometimes from suppliers from which you buy directly and through distributors is hard enough; much less via supermarket purchase. I'm not too familiar with kefir, but I would scope out all the suppliers of kefir in the supermarkets, and call each company's reps to inquire about documentation. Those that are willing to give documents would be the only ones I would be willing to buy from.

[GMO]

pHruit isn't sure that pHruit is right...

 

It's the sort of thing I could see many auditors easily overlooking, as if they picked out the ingredient as part of review of 3.5.1 then the "supplier" BRC etc is available.
It becomes more tricky if it's part of a trace exercise though, as that then opens the can of worms about what the "supplier" actually is.

Hopefully the OP will get some feedback from BRC on exactly how this is supposed to work.

 

Neither am I on reflection!  I was thinking about something we used to use only from retail markets and we had a spec the BRC auditor was happy with.  The difference is it was an ambient product though so it was limited how much could have gone wrong with it.  If a decent auditor dug into this for a chilled product, I'm pretty sure they would raise a non conformance.  If it was a conventional supply route, you'd expect the manufacturer not only to have a spec but also to ensure the wholesaler is approved (which is the supermarket supply chain and store in this case).  While there is an assumption that a supermarket supply chain is going to be compliant, it's not something I'd be that confident about.  There could also be multiple distributors, hauliers and logistics companies involved you have no knowledge of.  It certainly doesn't feel like it's in the spirit of BRC.