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[CSchmidt]

Question on 3.5.4.3 "Any outsourced processing shall:

• be undertaken in accordance with established contracts which clearly define any processing and/or packing requirements and product specification
• maintain product traceability."

 

Background: we are an edible bean (pintos, blacks, navy bean) elevator.  We're having another company mill and bag for us.  They receive raw dry beans from us, remove the Foreign Material, and bag in 100 lb bags (bags provided by us).  The process is dry and they are not changing the composition of the beans.  They arrive whole and leave whole.  They are also inspected & certified by a 3rd party certified grain inspection company before going to the customer. My question is how do I handle the traceability part of the this clause.  Do I need to trace from us providing the raw product to them?  Or do I need to follow the process through them to the final customer?  Or do I need to have them perform a trace for us? Thank you in advance for your help!

[pHruit]

You need to verify that your subcontractor has suitable systems to maintain traceability of their part of the operation - from point of delivery by you, through them, then back to you (or on to customers, if it is shipped/sold direct from the subcontractor).

You'd generally be expected to confirm that this is always the case based on them being able to show appropriate systems are in place, and you can treat this broadly as you would for other raw material suppliers - for example if they have GFSI-benchmarked certification then that would cover it (although personally I'd do an exercise too, because if nothing else it will be useful for you to understand how it works for them).