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How are brokered sales dealt with in SQF?


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APaetkau

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Posted 14 April 2021 - 01:38 PM

Hello, I work at a facility that processes dry edible beans (sold dry in bulk to facilities that either can or repackage)

 

I have been trying to find information on how brokered sales are dealt with in SQF. Currently our SQF plan states that we do not use contract manufacturers, but I recently found out our sales dept. has been acting as a broker (I found out when I received a claim from a customer with our company name on it.)

According to SQF v9 Co-Man is defines as "Facilities that are contracted by the SQF certified site to produce, process, pack and /or store part of or all of one or more products included in the site’s SQF scope of certification."

 

To my understanding this would include these brokered sales, or at a bare minimum the company packaging the product should be treated as a supplier, and go through the supplier approval process.

 

Is this correct, or am I just making more work for myself?

 

The answer I got from the SQF Practitioner at our parent company is that the claim wasn't meant to be sent to me in the first place, and there shouldn't be any claim in our records for the auditor to ask questions about.

 

Thanks in advance for any assistance!



Scampi

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Posted 14 April 2021 - 01:55 PM

honestly, i can way less about the contract manufacturing than i do about POTENTIAL RECALLS

 

whos keeping track of this movement

 

what if your beans contaminate another facility because there is a pathogen on them

 

etc etc etc

 

 

So I understand, your sales team is selling/moving your beans to another facility to pack them with your company name on them?  If yes, than yes you are correct


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APaetkau

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Posted 14 April 2021 - 02:11 PM

Sorry, I should have specified our facility never took possession of the product. As for recalls, as I was told I was never supposed to receive the complaint in the first place it was supposed to be dealt with through the corporate office and the other company. So I assume they have some form of traceability there



Scampi

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Posted 14 April 2021 - 02:16 PM

Ah, then it is NOT your concern

 

It has to do with head office and the 3rd party and not your site

 

SQF certification is site specific. Since you didn't receive the raw materials OR the finished goods you get to file under NMP  (not my problem)!


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APaetkau

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Posted 14 April 2021 - 02:23 PM

Even though the sale has our company name on it? I thought all product sold by the company needed to be covered by SQF.



Scampi

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Posted 14 April 2021 - 02:41 PM

Site specific--products produced at your site, under your SQF scope.  Since this is clearly not within your scope (you're going to want to check that), it is not your problem

 

 

As an example---the company I work for is National, we even ship materials between 2 sites daily, but we EACH get an independent audit (some of our sites are BRC some are SQF) and we get audited on our scope.  What another site, across the country, does has no bearing on my audit or responsibilities

 

That doesn't absolve the company of responsibility, but it does absolve you


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APaetkau

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Posted 14 April 2021 - 02:44 PM

Ok, this is great. I wish the other guy had told me that instead of just telling me not to show the auditor.

This is a huge load off my mind, you are my hero, thanks!!



Scampi

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Posted 14 April 2021 - 03:15 PM

The other guy clearly doesn't understand/or is involved in/scope decisions!

 

 

My #1 piece of advice for you-----get as close to memorizing the code as you can........it will save you in countless ways!


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SQFconsultant

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Posted 14 April 2021 - 03:19 PM

If you have an outside company making and packaging the produxt under your label it does not matter whether they ship the product to your facility or if they ship the product on your behalf to others - your responsiblility under SQF is to follow and adhere to the requirements for contract nanufacturers, their is no go around andcfrom the fweling that your corporate office seems to be sneaky sneaky with what should have not been sent to you I susoect there is a breakdown here - and that will impact your certification if their are tracking/ recalls.


Kind regards,
Glenn Oster
 
GOC BUSINESS GROUP | SQF System Development, Implementation & Certification Consultants
Internal Auditor Training - eConsultant - Pre & Post SQF-GAP Audits - Consultant Training
Visit us @ http://www.GlennOster.com  or call us @ 772.646.4115 US-EST 8am-4pm Anyday except Thursday
 
 

SQFconsultant

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Posted 14 April 2021 - 03:21 PM

I have a messed up auto correct on my phone, sorry for all the glitches in that response... ugh!


Kind regards,
Glenn Oster
 
GOC BUSINESS GROUP | SQF System Development, Implementation & Certification Consultants
Internal Auditor Training - eConsultant - Pre & Post SQF-GAP Audits - Consultant Training
Visit us @ http://www.GlennOster.com  or call us @ 772.646.4115 US-EST 8am-4pm Anyday except Thursday
 
 

APaetkau

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Posted 14 April 2021 - 03:30 PM

From what I can tell the product does not have our label / brand on it, I assume it was our company name on the bill of sale though.



Scampi

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Posted 14 April 2021 - 03:38 PM

I'm curious to see Glenns response

 

Not labelled with company name

 

Sales team PROCURES the raw material ONLY---aka broker


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SQFconsultant

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Posted 14 April 2021 - 04:25 PM

Well, that changes things a bit doesn't it scampi!

We actually had a client - a family operation that wanted us to develop their SQF programs which we did.

But at the beginning we always have a meeting to discuss potential issues that we may run into along the way.

One of the questions had to do with suppliers, how many, if their were brokers, did their sales team ever outsource buying product that shipped by the supplier direct to the customer etc.

Same thing here it appears.

We would come to find out they had about 125 suppliers and in those ten or so that shipped direct to the customer - but on behalf of the sales team/xyz company.

For all intents and purposes as a customer to the sales team/xyz company I would the understanding that I was buying the product via the xyz company regardless of what entity shipped it to me.

Boil down - we had the sales/buyer team disclose all the sources they dealt with in this way and qualified them as approved suppliers.

They all went thru the process of getting approved, granted in some respects it was like pulling teeth with a sales team and brokers where they have always done business this way and nothing ever happened.

That was however until a customer of xyz called and said they discoved metal filings in several bags of product requiring a recall and since they purchased this from xyz... xyz had involvement in the mix.

Granted we could say out of sight, out of mind however as a stone flipper consultant I see the risk first - even if remote and if their is the slightest risk and tossed in is a helping of we've akways done it this way by a sales team that many times skirted food safety or ignored the fact they could be playing with the actual monster in the corner of the room... you get the picture.

Ignoring it can impact the company and the SQF certification too.

Interestingly enough during this teeth pulling process with the sales/buyers team we actually identified three suppliers that were shipping product from illegal locations and a couple of one man operations that had regulatory actions against them... what a time.

So, I'd be discussing this with sales, value of the process, how it could impact current certification etc.

The issue is a document pops up and now you know about a side thing that is being done - you can't just forget about, but need to take action.


Kind regards,
Glenn Oster
 
GOC BUSINESS GROUP | SQF System Development, Implementation & Certification Consultants
Internal Auditor Training - eConsultant - Pre & Post SQF-GAP Audits - Consultant Training
Visit us @ http://www.GlennOster.com  or call us @ 772.646.4115 US-EST 8am-4pm Anyday except Thursday
 
 

Scampi

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Posted 14 April 2021 - 04:42 PM

But wouldn't brokered sales have to be within the scope Glenn?


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SQFconsultant

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Posted 14 April 2021 - 04:56 PM

The only way to make the brokered sales exempt is to ensure it is a separate entity.

As in, a separate company - it could operate under the same roof but customers of the sales team would have the outside brokers/suppliers ship not under the current company name but must be a different one.

And yes, we have been involved in setting these up.

This would be an in house brokerage where the product is not on the scope and for all intents and purposes the customer thinks and sees they are dealing with the abc and not the original xyz company.


Kind regards,
Glenn Oster
 
GOC BUSINESS GROUP | SQF System Development, Implementation & Certification Consultants
Internal Auditor Training - eConsultant - Pre & Post SQF-GAP Audits - Consultant Training
Visit us @ http://www.GlennOster.com  or call us @ 772.646.4115 US-EST 8am-4pm Anyday except Thursday
 
 

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APaetkau

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Posted 14 April 2021 - 05:56 PM

Ok, thanks Glenn. Less happy to hear that, not something I wanted to have to deal with 2 weeks before our audit, but I really appreciate your feedback.

Stone Flipper consultant sounds like a lot more fun than this job!






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