Difficulty on getting COAs from suppliers

Hello,

I work at a small ice cream chain that has begun selling their product wholesale, which of course opens us up to FDA inspections and has us reevaluating our food safety plan. We are now requiring COAs for every ingredient that we bring into the store that doesn't have some sort of kill step post-delivery. However, some of our biggest and most important ingredients have been very difficult and claim they don't supply COAs. Some examples include Oreos, Cereals such as cinnamon toast crunch, and salty caramel bases. What I am asking is how should I approach this situation? Is there any reason as to why these ingredients might be an exception and not require a COA to use in production? Is there any other documentation that these companies might provide that would suffice? Our 3 most popular flavors require Oreos so we are very dependent on using them as an ingredient, but our top priority is food safety so this has really put us between a rock and a hard place, any assistance or direction would be greatly appreciated! Thanks!

-Brian P.

Ask the ingredient suppliers to provide a continuous LOG - that would suffice.

Did you reach out to the manufacture (general mills I think) directly?  Assuming you're using a distributor and not buying direct

No, you MUST have either a CoA or a continuous LOG to demonstrate what your using is fit for use

Thank you for the response! Just to clarify I am in the states, I see your located in Toronto so I'm sure there could be some slight differences in our rules and regulations. Do you know for sure that would be sufficient for Wholesaling in the U.S.?

Ask the ingredient suppliers to provide a continuous LOG - that would suffice.

We did reach out to general mills but they told us that they don't supply COAs, I will reach back out to them and see about getting a continuous LOG though, appreciate the feedback

Did you reach out to the manufacture (general mills I think) directly?  Assuming you're using a distributor and not buying direct

 

No, you MUST have either a CoA or a continuous LOG to demonstrate what your using is fit for use

Hello,

 

I work at a small ice cream chain that has begun selling their product wholesale, which of course opens us up to FDA inspections and has us reevaluating our food safety plan. We are now requiring COAs for every ingredient that we bring into the store that doesn't have some sort of kill step post-delivery. However, some of our biggest and most important ingredients have been very difficult and claim they don't supply COAs. Some examples include Oreos, Cereals such as cinnamon toast crunch, and salty caramel bases. What I am asking is how should I approach this situation? Is there any reason as to why these ingredients might be an exception and not require a COA to use in production? Is there any other documentation that these companies might provide that would suffice? Our 3 most popular flavors require Oreos so we are very dependent on using them as an ingredient, but our top priority is food safety so this has really put us between a rock and a hard place, any assistance or direction would be greatly appreciated! Thanks!

 

-Brian P.

For the cereal and cookies - another thing you can do - determine the hazards. Then ask for documentation that they are controlling these hazards.(#3) So for example - the cereal would have a cooking step.

You could also yourself test the items once received in (#2).

Another option - (once allowed d/t COVID) - do a onsite audit of the facility (#1)

117.410   General requirements applicable to a supply-chain program.

(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.

Request a letter of guarantee as one of the posts stated above. Unless you're buying these ingredients by the truck load/rail car, do not expect to get a COA with every load received.

Request a letter of guarantee as one of the posts stated above. Unless you're buying these ingredients by the truck load/rail car, do not expect to get a COA with every load received.

You can see if a LOG will work. For the USDA - these are fine but for the FDA - maybe? During the FDA federal inspections I've been through - a LOG was not sufficient enough.

You can see if a LOG will work. For the USDA - these are fine but for the FDA - maybe? During the FDA federal inspections I've been through - a LOG was not sufficient enough.

I worked at a produce wholesaler. We could not get COAs from our suppliers to save our lives.

It's understandable for a larger operation, but not for a few cases of product.

I do not see vendor providing a COA for every case of a few cases of product. Again, for a railroad car full of product, yes, that is reasonable and that's different.

We had this same conversation with the FDA and they pointed out they were adamant about COAs because they are reading that from the FSPCA PCQI participant manual and basically going by the examples used in the course.

A COA is one way to control a hazard, but so are audits & supply chain preventive controls, such as a robust supplier approval program.

if your program requires COAs, this makes your program incredibly rigid and backs you into this corner where you are forced into receiving COAs.

You could go back and review what your procedures for evaluating your supplies / suppliers are.

If you are a small entity, then you could be dealing with wholesalers and not the manufacturer themselves. As such, you may try requesting documentation from the wholesaler instead of the manufacturer.

As already mentioned above, the CoA is only one way for suppliers to assure the safety of their products. For small holdings typically Letters of Guarantee are more applicable.

You could go back and review what your procedures for evaluating your supplies / suppliers are.

If you are a small entity, then you could be dealing with wholesalers and not the manufacturer themselves. As such, you may try requesting documentation from the wholesaler instead of the manufacturer.

As already mentioned above, the CoA is only one way for suppliers to assure the safety of their products. For small holdings typically Letters of Guarantee are more applicable.