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BRC Management of Suppliers of Raw Materials and Packaging

Growers suppliers

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Posted 30 March 2020 - 11:48 PM

We are a single ingredient provider who sources almost all our products directly from the growers who plant under contract to our company (pulses, cereals and oilseeds).


These vary from medium sized corporates (small percentage) to sole-proprietor family-owned businesses.  In our network, which is in the hundreds, there would not be a single GFSI certified company so we would be relying on a completed supplier questionnaire (which we've done for decades anyway).


The current questionnaire asks a series of food safety and quality issues, as does the contract that is completed prior to the purchase of the product (in most cases before the crop is even planted).


It seems to me that this would be sufficient but I would be interested in the views of others on this scenario.



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Posted 31 March 2020 - 01:46 PM

In a general sense yes, I think this sounds like it could be reasonable, but as an outsider with no detailed information it's not really possible to say this with any certainty.

Your challenge is to justify the position - being comfortable with it for your own purposes is good in the sense that you hopefully know you're buying safe ingredients, but you've then got to be able to demonstrate this to the people auditing you.

In effect  you're using the third option in clause, so you'll need to come up with the "valid risk-based justification". The interpretation guide mentions "the output of clause" in this context, so have you completed that risk assessment and determined the raw materials involved to be low risk?
If so, you can then feed this into the second risk assessment you're doing for clause and, assuming that the overall result is that these suppliers are low risk, and you've used a sensible method that you can defend when scrutinised, then you should be ok to adopt the questionnaire-based approach.

If you're not physically purchasing direct from the growers then it's also worth having a think about the traceability requirements in clause, as it's an easy one to complete at the same time as getting your suppliers to complete the questionnaires, but you may not need to do this if you're only sourcing direct from farm.

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Posted 01 April 2020 - 03:24 AM

Thank you for your response. You are quite right to point out that a determination is difficult to make from a forum post, but your response is helpful!


After reading your response I went back through and again and looking at our contracts with the growers and the questionnaire, (which is actually a binding declaration), combined with multiple farm visits by company reps as well as an exhaustive risk analysis and inspection of goods received, that I'd be able to adequately explain our position that the growers are low risk, especially since we have the right to reject any crop on receival if it does not meet our standards outlined in the contract (or if they declare anything improper in their questionnaire/declaration).


Thanks again for your thoughtful response.

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