9 replies to this topic

[David McArthur]

I am sales manager for a bakery ingredient distributor with over 1400 sku's. We try and collect Coa's on all items.

Currently my director is not allowing me to bring in new product with out them. They claim that it is a FDA foods safety law requirement. Is that true or is it just good food safety practice. We have very few customers currently requiring Coa's. And it is a huge manual time and expense factor to implement. It is also curtailing my ability to rapidly reply to customers request for new items... HELP!!!!!

David

[pHruit]

Are you not obtaining any other supplier approval information for your products?

I'd have thought that obtaining CofAs is fairly trivial as part of the process of checking certification, obtaining specifications, verifying basic regulatory compliance etc for each ingredient?
(I say this as the person responsible for technical/regulatory/QA/QC functions in a business that handles 2000+ SKUs)

 

Doing things correctly often has a cost, unfortunately. I could fill up my diesel car with petrol as it's cheaper, but it doesn't make it a good idea

I've been through similar challenges to the one that it sounds like you're facing. Two main points that helped my commercial colleagues understand a bit better:

1) The industry is moving towards ever more thorough standards. This is broadly a good thing, as safer food means fewer people harmed. Given that it's going that way, you may as well turn it to your advantage and get out ahead of it.

2) Moving quickly isn't a positive thing in and of itself - it's only a useful mechanism if it allows you to create sustainable long-term business. This can be achieved to an extent through luck, but that only goes so far - when you start cutting corner things eventually go wrong, and that has a cost either directly or in loss of repeat business opportunities.

 

There is a balance to be struck, and I think you will find that even here there are a lot of people who will agree that elements of the industry have lost their marbles and gone a bit OTT in some areas, but equally there is a minimum that reasonably needs to be done to ensure products are still safe and correct. Talk to your colleagues in QA, explain the predicament, and work with them to find the best balance you can for your situation. I've seen companies that turn around new products in a day - it's often too fast, things get missed, customers are unhappy (at best - at worst you're potentially harming consumers). I've also seen companies that may take 3-6 months to set up a new product due to byzantine and inflexible procedures, and lost opportunities as a result of it. Between these two extremes there is a large expanse of middle ground in which you should be able to find a sensible compromise, but it takes co-operation and understanding.

Given that your responsibility is sales, I'd also strongly recommend using this as a positive when talking with customers - yes it might take two days instead of one, but that's because you want to do it well, and that is something that is appreciated in the long term

[QAGB]

I can't speak for non-GFSI, but for GFSI standards like BRC/SQF/FSSC, you'd want to have your COAs on file. While it may seem like a hassle (and it is), these files can be pretty important.

 

• You'll probably need COAs to assess your ingredient hazard risks, and possibly your process hazard risks. You need to know what testing your supplier is doing to ensure your products will be as you expect them to be when you receive them.
• You'll want to have these at receipt in case you need to reject product (unless you plan on testing every one of your SKUs for necessary analyses).
• These are usually associated with your supplier approval and ongoing review processes.
  • BRC specifically states: "a company shall have a procedure for the acceptance of raw materials and primary packaging on receipt based upon risk assessment. Acceptance of raw materials and their release for use shall be based on either one or a combination of: product sampling and testing, visual inspection on receipt, certificates of analysis, certificates of conformance."
  • Furthermore, "a list of raw materials and the requirements to be met for acceptance shall be available. The parameters for acceptance and frequency of testing shall be clearly defined, implemented, and reviewed

Therefore, is it an absolute must to have a COA? No. You can sample and test (as long as your testing requirements meet regulations and customer standards). For products that may be minor, low risk ingredients, you could do visual inspections (especially if their attributes do not have much of an effect on finished goods). Or, you could file your COAs and COCs as part of your raw material acceptance. 

 

Given under BRC you would have to have a list of materials and their requirements, you'd best be doing what you say you are doing. Not having a COA for an item where you said having a COA is a requirement is grounds for a non-conformance.

 

Again, this is more for GFSI certification - but you should want to have COAs on file to ensure that you are receiving in safe, quality, product.

[SQFconsultant]

Your supplier approval process should make it mandatory for a COA, inspection or GFSI compliance, etc.  This is something you should have for products/supplier.

[David McArthur]

We do all the prior paperwork. For example, 100gram, sugar breakdown, kosher cert, sanitation and compliance certs. etc all on file for everything prior.

It's just COAS that are a continuing hang up. generaly when purchasing from a redistributor. Example DOT foods does not offer a program to supply COA's. And small specialty suppliers also face same problems.

And based on the feedback. It's not FDA law. But is something needed for those who require the coa. Like most of our large customers do and of which we provide. But over 1/2 of our business is to individual owner bakery / donut shop  type customers who require no paperwork as they do not fall under most labeling laws. And these are the coa's that usually never show up or the provider does not have the system for same.

 

Thanks for the comments

David

[QAGB]

We do all the prior paperwork. For example, 100gram, sugar breakdown, kosher cert, sanitation and compliance certs. etc all on file for everything prior.

It's just COAS that are a continuing hang up. generaly when purchasing from a redistributor. Example DOT foods does not offer a program to supply COA's. And small specialty suppliers also face same problems.

And based on the feedback. It's not FDA law. But is something needed for those who require the coa. Like most of our large customers do and of which we provide. But over 1/2 of our business is to individual owner bakery / donut shop  type customers who require no paperwork as they do not fall under most labeling laws. And these are the coa's that usually never show up or the provider does not have the system for same.

 

Thanks for the comments

David

 

 

Answering your question: COAs aren't required by FDA Law.

 

However, your QA Department owns the COA process, and they need to decide what incoming items will require a COA. In your case, maybe you do testing on your major ingredients, and then you use COAs and COCs for minor ingredients. However, regulating of those procedures is ultimately up to your QA team. 

 

We all do recognize that trying to procure COAs and file them away can be an annoyance, but I don't see how you would manage without at least COAs for certain products.

 

 

In a previous life - we required COAs for all minor ingredients (and we had a list of those minor ingredients) where the finished product isn't much affected by the addition or subtraction of those ingredients (and ingredient considered low risk). We used those in place of having to analyze these ingredients on site. We also conducted visual inspections for all bulk ingredients that didn't arrive in a tanker.

 

We also wanted COAs for major ingredients, but were not considered a must have because we did our own testing on-site for attributes necessary, and records were kept.

 

There should be no reason why DOT Foods or your small suppliers couldn't get you a COA upon request. When your company places orders, it should be required and listed on the Purchase Order to the supplier that "All orders must have COA accompanying order or e-mailed to xxxxxx - otherwise subject to rejection". If they legitimately cannot provide you with a COA, then you certainly have a reason to look for another supplier.

Edited by QAGB, 04 November 2019 - 09:36 PM.

[The Food Scientist]

I am sales manager for a bakery ingredient distributor with over 1400 sku's. We try and collect Coa's on all items.

Currently my director is not allowing me to bring in new product with out them. They claim that it is a FDA foods safety law requirement. Is that true or is it just good food safety practice. We have very few customers currently requiring Coa's. And it is a huge manual time and expense factor to implement. It is also curtailing my ability to rapidly reply to customers request for new items... HELP!!!!!

David

 

So how are you ensuring your raw material is SAFE? Unless YOU are testing them in-house/3rd party lab prior to releasing then COA's wont be needed from suppliers. (Your own coa's)

[kfromNE]

The current FSMA law - so while CoA's are required by the FDA, they are a way to verify your raw materials and other ingredients. If you don't require CoA then you will have to do one of the other listed below. So in the plant I work, instead of a CoA, the supplier would be required to give us their full GFSI audit to prove they are controlling for the different hazards that may be associated with their product (these hazards are taken from Appendix 1: Potential Hazards for Foods and Processes). Just a letter of guarantee won't cut it either - this is according to the FDA inspectors when we were inspected.

 

 

PART 117 -- CURRENT GOOD MANUFACTURING PRACTICE, HAZARD ANALYSIS, AND RISK-BASED PREVENTIVE CONTROLS FOR HUMAN FOOD

Subpart G--Supply-Chain Program

Sec. 117.410 General requirements applicable to a supply-chain program.

 

(a) The supply-chain program must include:

(1) Using approved suppliers as required by 117.420;

(2) Determining appropriate supplier verification activities (including determining the frequency of conducting the activity) as required by 117.425;

(3) Conducting supplier verification activities as required by 117.430 and 117.435;

(4) Documenting supplier verification activities as required by 117.475; and

(5) When applicable, verifying a supply-chain-applied control applied by an entity other than the receiving facility's supplier and documenting that verification as required by 117.475, or obtaining documentation of an appropriate verification activity from another entity, reviewing and assessing that documentation, and documenting the review and assessment as required by 117.475.

(b) The following are appropriate supplier verification activities for raw materials and other ingredients:

(1) Onsite audits;

(2) Sampling and testing of the raw material or other ingredient;

(3) Review of the supplier's relevant food safety records; and

(4) Other appropriate supplier verification activities based on supplier performance and the risk associated with the raw material or other ingredient.

[The Food Scientist]

Honestly you're considered lucky your "director" ,someone from top senior management actually cares and agrees that coa's should be needed for every ingredient. Many don't care and that causes so many issues in commitment to food safety. I am assuming you're not involved much in Food Safety since you are a Sales Manager?

[David McArthur]

Don't get me wrong. Food safety is a top priority for me as sales manager also. and We get coas on every raw ingredient. Our major raw suppliers. Never a issue. Flour, sugar, oils, etc.

The items that pose the most problems are manufactured items that we are reselling. Baked pie shells, Chocolate ganache, (right now issue is Oreo's), Mondaleze is terrible to work with.. And small ticket volume items. Some items we only special order and move 2-3 a year. But have 50 customers like that. These are the one that drive you nuts. And take forever. So customers today. Jump on the web. Or go to restaurant depot and buy it because they don't have FDA or other inspections on ingredients.

It all adds up.