3 replies to this topic

[P-J]

We are a UK based Logistic and cold storage company. All product is in either 3rd/4th & 5th layer of packaging and all stock is owned by the customer.  I have a customer from the USA that wants us to full in a Allergen matrix asking us to identify all allergens onsite. Hard to do when outer labels on pallets do not say. Also to sign a Letter of Guarantee which states 'we will adhere to

 

1. Carried out in full compliance with all applicable Canadian or US Federal, State or Provincial statute or regulation, including with limitation the Food and Drug Act of Canada, and the Food, Drug and Cosmetic Act of the U.S.A.; the Public Health Security and Bioterrorism Preparedness and Response Act of 2002 ("the Bioterrorism Act"),

2. Not in contravention or violation of any applicable regulations of any other regulatory governmental authority.

 

As UK based and hold only BRC Storage & Distribution 3 at AA grade, this is not GFSI recognised QMS (Unlike BRC FOOD 8) so we can not possibly sign such?

 

Any assistance gratefully received.

Thank you

[Dr.Khan]

Hi P-J

 

As you mentioned all stock is owned by customers. To Resolve this issue you can send the same letter to the suppliers of the products you purchase or the customer who is asking you to sign the letter.

you can then send the copies of the letter to this customer. Yu can sign the requested letter with addition of the folwing statements.

 

Based on the statements made in writing by the suppliers of the following products we are pleased to sign this letter.

 

 

Kind regards

Dr Humaid Khan

MD Halal International Services

Australia

[pHruit]

We are a UK based Logistic and cold storage company. All product is in either 3rd/4th & 5th layer of packaging and all stock is owned by the customer.  I have a customer from the USA that wants us to full in a Allergen matrix asking us to identify all allergens onsite. Hard to do when outer labels on pallets do not say. Also to sign a Letter of Guarantee which states 'we will adhere to

 

1. Carried out in full compliance with all applicable Canadian or US Federal, State or Provincial statute or regulation, including with limitation the Food and Drug Act of Canada, and the Food, Drug and Cosmetic Act of the U.S.A.; the Public Health Security and Bioterrorism Preparedness and Response Act of 2002 ("the Bioterrorism Act"),

2. Not in contravention or violation of any applicable regulations of any other regulatory governmental authority.

 

As UK based and hold only BRC Storage & Distribution 3 at AA grade, this is not GFSI recognised QMS (Unlike BRC FOOD 8) so we can not possibly sign such?

 

Any assistance gratefully received.

Thank you

 

The detail you've shared doesn't appear to mandate GFSI-benchmarked certification as a requirement, so that wouldn't preclude you signing?

 

Hopefully part (2) is relatively easy - "applicable regulations" will be those in the UK, since that is where you're operating.

 

For (1), are you storing for a US client who is using the stock in the UK, i.e. you have no actual involvement with the US/Canada?

If so then I'd ask if they can provide more detail on their expectations. We get questions like this occasionally, usually from very large businesses, who understandably seem to send out standardised requirements as part of their QA "machine", and when questioned are usually quite open to the notion that some of what they're asking for is nonsensical - in these circumstances we usually agree to replace with some more relevant UK equivalent. And where they don't agree, we simply cross this bit out, initial it, write that we're in compliance with applicable European and UK regulations, then sign and return. It's not always popular, but we've tried to agree a sensible resolution, and I'm not signing something we don't do and have no reason to do 

 

For the allergens question, I'd simply advise that your allergen controls are in accordance with BRC requirements. You could try the approach of stating that the nature of other products is confidential as they are owned by other clients, and surely the customer would want you to honour the same degree of confidentiality for their ingredients?

Alternatively you have no option but to contact all of your customers to obtain allergen details, and also then implement some sort of agreement that they would have to notify you in advance if this changes. I do know of some fairly large storage providers who do just this, so it can be done. Having said that, one of the larger ones has recently notified us that they will no longer store certain allergens as some clients' segregation and handling requirements were becoming unmanageable...

[P-J]

Thank you for the replies.

 

I have to say that you have confirmed my thoughts as I prepare a letter with regards to EU and UK regulations as oppose to signing against USA/Canadian regs.

 

Again thank you very much