Is supplied noodle and our sauce in a box an outsourced product?
I have a question regarding Management of outsourced processing.
Actually we are sauce manufacturer certified by BRC and IFS. Now we want to do new product where we will buy noodle from our supplier and pack together with our sauce in unit box (instant noodle product).
Will this consider as outsourced product? As we only buy instant noodle from them and the packaging using our brand. For my understanding, we just put under supplier control.
I hot ask the same question to BRC & IFS auditor. Both has different answer, BRC auditor said just declare as exclusion from our scope (actually our scope only mention about sauces not noodle) while IFS auditor said must declare outsourced product.
This is my 1st posting. Really need someone help me as I'm stuck with this issue.
I'm sorry if my English not so good.
Interesting question!
Can't comment on the IFS part, and honestly not entirely sure on the interpretation from the BRC end of things either.
The glossary in the current BRC standard defines "outsourced processing" as: Outsourced processing is where an intermediate production process or step in the manufacture of a product is completed at another company or site.
This seems to be in general accordance with e.g. the requirements in 2.5.1 and 3.5.4.
The key question is perhaps whether adding the finished (packed?) noodles into your outer packaging counts as a manufacturing stage. If they are open/exposed at this point then probably yes, and you should look at 2.5.1 and 3.5.4. If the noodles are already packed and you just put this into another outer pack unit then potentially not. Might possibly sit within the traded goods requirement instead, rather than being truly outside scope, but it would be a slightly weird position given that it's all sold as one product.
Auditors interpretations can vary and aren't always correct for more unusual questions, so in your position I'd contact the certification body and ask if you can discuss it with their technical department.
Excluding things from the audit is never a good idea - the certification process can add so much value to a brand, leaving parts out lessens the value, and leaves exposed weaknesses in your product safety and quality plan.
Given the needles are being purchased, to be combined with other things (your sauce, the packaging), into a finished product, the noodle is essentially an ingredient, and should be treated as such. The only adjustment may be to your stated scope, to clearly show you produce sauce and assemble along with noodles produced elsewhere.
Nice to see the growth!
Interesting question!
Can't comment on the IFS part, and honestly not entirely sure on the interpretation from the BRC end of things either.
The glossary in the current BRC standard defines "outsourced processing" as: Outsourced processing is where an intermediate production process or step in the manufacture of a product is completed at another company or site.This seems to be in general accordance with e.g. the requirements in 2.5.1 and 3.5.4.
The key question is perhaps whether adding the finished (packed?) noodles into your outer packaging counts as a manufacturing stage. If they are open/exposed at this point then probably yes, and you should look at 2.5.1 and 3.5.4. If the noodles are already packed and you just put this into another outer pack unit then potentially not. Might possibly sit within the traded goods requirement instead, rather than being truly outside scope, but it would be a slightly weird position given that it's all sold as one product.
Auditors interpretations can vary and aren't always correct for more unusual questions, so in your position I'd contact the certification body and ask if you can discuss it with their technical department.
Hi pHruit,
Thank you so much for your kind reply. Actually the noodle is packed noodle. We dint open @ process in further. We just pack the packed noodle + our sauce (in sachet) into the unit box.
We just treat the supplier as same as supplier control (questionnaire, product spec, allergen + GMO declare). It is enough, or I need to new procedure on outsourced process?
Once again, thank you so much for your kind help.
Excluding things from the audit is never a good idea - the certification process can add so much value to a brand, leaving parts out lessens the value, and leaves exposed weaknesses in your product safety and quality plan.
Given the needles are being purchased, to be combined with other things (your sauce, the packaging), into a finished product, the noodle is essentially an ingredient, and should be treated as such. The only adjustment may be to your stated scope, to clearly show you produce sauce and assemble along with noodles produced elsewhere.
Nice to see the growth!
Hi John,
Thank you so much for your reply. Actually the noodles is packed noodle. We dint do anything on the product, just pack together with our sauce (in sachet) into the unit box. Should I treat the supplier as others supplier that provide raw materials to us? Ask them to fill up supplier questionnaire, product spec, allergen + GMO declaration and do risk assessment & vulnerability assessment. And go to their site and audit them.
It is enough @ should I create new procedure for outsourced processing?
Once again, Thank you so much for kind reply.
Hi pHruit,
Thank you so much for your kind reply. Actually the noodle is packed noodle. We dint open @ process in further. We just pack the packed noodle + our sauce (in sachet) into the unit box.
We just treat the supplier as same as supplier control (questionnaire, product spec, allergen + GMO declare). It is enough, or I need to new procedure on outsourced process?
Once again, thank you so much for your kind help.
I don't know if that makes it more or less complex!
(Although for what it's worth, you should absolutely take Mr Kukoly's advice in preference to mine given that he's a senior member of the BRCGS team whereas I'm just another idiot on the internet ;) ).
To my reading, the reference to intermediate product in the "outsourced processing" definition could be read in two ways in the case of your product - the noodles are finished/packed in and of themselves, but equally they are a component (albeit not further processed in any way) of your overall final product.
Personally I think I'd cover the requirements for 2.5.1 / 3.5.4 as you can rarely go wrong by giving extra consideration and for your own purposes you may identify risks that you can improve control of by going through the process, and if nothing else it's better than not doing it and then finding that the auditor thinks it should have been done.
I still think it's worth asking your certification body to check with their technical department, if only to give you a bit more certainty as to where it sits. Unless Mr. Kukoly chimes in with further input ;)
pHruit - you have it right, in your definition of outsourced processing. Smart idea as well, to vet whatever direction is taken with the CB well in advance of the audit.
This is one of those instances where the activity isn;t perfectly covered in the Standard, so you have to step back a bit and assess the why rather than the what - less time trying to put a label on what you're doing, more time doing a good job of identifying and managing the risks.
Regardless of what it's called:
1. identified as an input in the food safety plan
2. there is an approval and monitoring mechanism that is followed
3. the noodles have a complete specification
4. the noodles are fully traceable
5. the noodles go through an appropriate receiving process
If you cover the potential risks, there isn't much difference what it gets defined as.
Hi folks,
this is my first post and I have benefitted form the exchange above.
my question is: if we are using a co-packer but we are located in the same multi-level building (i.e. product is piped in and never left the 'site'), I'm inclined to say we have a outsourced process.
happy to hear your thoughts on this?
Ray
Hi folks,
this is my first post and I have benefitted form the exchange above.
my question is: if we are using a co-packer but we are located in the same multi-level building (i.e. product is piped in and never left the 'site'), I'm inclined to say we have a outsourced process.
happy to hear your thoughts on this?
Ray
Welcome to the forum :welcome:
Is this a part-finished product that comes back from your co-packer/outsourced processor, or are they delivering (albeit to another unit in the same building) a finished product?
"Piped in" makes it sound like an actual outsourced process, but if they're truly a co-packer, i.e. they're making an actual final product for you, then I'd still call them a co-packer - the standard doesn't really differentiate between whether the co-packer is next door or 3000 miles away ;)