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Supply chain requirements...finding it difficult to get COA's


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#1 The Food Scientist

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Posted 30 January 2020 - 06:29 PM

As we all know one of the biggest PAINS in food business is the food supply chain. I am trying to find and know the correct procedure in place to stay in compliance with federal regulations.  Any help would be appreciated.

 

So we purchase candies from a supplier. These candies are either in bulk not individually packaged (gummy worms) and some come in bulk but individually packaged (packaged lolipops. both of these types go in bags, which is done by us. (so some go in primary packaging and some in secondary. 

 

This supplier buys it from an IMPORTER. This importer is in the USA and they buy from their company in Mexico. So it really is the same company in Mexico in USA but they have their office here where they import it from their manufacturing site in Mexico. 

 

SO:

 

Manufacturer (Mexico) - Importer (USA)-  Buyer from Importer (USA) - Then us. 

 

So we dont get any COAs of these candies. The buyer from the importer say they dont require their importer any documentation (weird since importer must follow FSVP). So in turn I am not receiving any COAs of these candies! And I need to! It's frustrating since importer should request them from the manufacturer and they must be forwarded down the supply chain leading to us, CORRECT?

 

Any help on what I can do?? Has anyone been in this situation? Any regulation maybe I am missing on these candies? 


Everything in food is science. The only subjective part is when you eat it. - Alton Brown.


#2 crystalbee

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Posted 30 January 2020 - 07:27 PM

Hi Food Sci, we are in a similar scope (confections that we do not manufacture, but purchase and then package ourselves). I had the same issue with you with COAs being neglected. We purchase from Mexico as well.

Can you directly contact the manufacturer to get one? That is what I did when an importer could not supply one. You are correct in your supply chain statement - for us it was particularly urgent since we were about to audit which is why I contacted the manufacturer as a last resort.

We also send product (before purchasing / pre-production samples) and test ourselves, which our auditor mentioned could bypass COA if we wanted to.

 

Perhaps your purchasing or buyer should address this in to the importer when purchasing (making a note in the PO) - or creating a training with relevant staff on what should be expected of documentation when buying in the first place? I know this was the game changer for our company in keeping up compliance - to only purchase from suppliers that can comply with your documentation standards.


Edited by crystalbee, 30 January 2020 - 07:35 PM.


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#3 kettlecorn

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Posted 30 January 2020 - 07:28 PM

This is from the FDA's Foreign Supplier Verification Programs for Importers of Food for Humans and Animals:Guidance for Industry:

 

F.19 Q: When might sampling and testing of food be an appropriate supplier verification activity?
 
A: Testing of in-process materials, environmental samples, or the food produced by the supplier may be an appropriate supplier verification approach if such testing provides meaningful results relating to control of a hazard requiring a control. Depending on the circumstances, you, your foreign supplier, or another entity might conduct the sampling and testing. For example, you might ask your supplier to conduct sampling and testing and provide the results in a certificate of analysis (COA).
 
[...]
 
As an example of use of sampling and testing as a verification method, if you import a packaged mix of food seasonings, you might conduct your own periodic Salmonella testing or use a contracted laboratory to test samples of the seasoning mix on a monthly basis. This monthly testing could be conducted until a good history is established for the seasoning mix supplier, after which time you might determine it would be appropriate to test less frequently, such as quarterly.
 
Alternatively, you might determine that it is appropriate to obtain documentation (such as a COA) of lot-by-lot or periodic testing of the food that is conducted before the food is distributed by the foreign supplier. We recommend that a COA document that major analytical parameters for a specific food or lot in a specific shipment have been met (see, e.g., Grocery Manufacturers Association, ‘‘Food Supply Chain Handbook’’ (http://www.gmaonline...upplyChain2.pdf), April 16, 2008). The testing might be performed by the supplier’s in-house laboratory or contracted to an outside testing laboratory
 
***
 
Personally, I don't see it written in code that a COA is required for FVSP. But our company deals only with suppliers that supply one. It's simply a requirement of doing business with us; otherwise, we'll find someone else. You may want to phrase it that way to make your case. 

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Edited by kettlecorn, 30 January 2020 - 07:30 PM.


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