Certificates of Analysis for retail type ingredients

We purchase some ingredients for use in formulations in a hot fill hold operation which are available at retail stores such as Cash & Carry and such.  Examples - canned beets, canned tomatoes, coffee, in retail packaging.  Are we required to get certificates of analysis for such items? They can be extremely difficult to get.  Thanks in advance.  

My company also purchases some raw materials from retail locations because the quantities we purchase are small enough that retailers provide the most competitive pricing.  Because these raw materials come from retail locations, we consider them fit for use and exempt them from the our Approved Supplier Program.  We do list them on our Supplier Register and put the supplier as "Retail".

Thanks for your reply - we have been trying to get COAs whenever possible and it's tough.  I like your approach and I agree with it.  Are you SQF/BRC etc. certified, and is this satisfactory to your auditing body?

My company also purchases some raw materials from retail locations because the quantities we purchase are small enough that retailers provide the most competitive pricing.  Because these raw materials come from retail locations, we consider them fit for use and exempt them from the our Approved Supplier Program.  We do list them on our Supplier Register and put the supplier as "Retail".

Hi Spidey,

Frankly I am extremely surprised/amazed if your " SAP bypass"  approach was auditorially acceptable. Similar queries have come up a few times on the Forum and IIRC the usual consensus for any GFSI, FS Standard has  been "unacceptable". The solution - find another source.

One time such a Procedure is IMEX considered acceptable is typically referred to as an "emergency" situation eg where the stock of some Production item has unexpectedly/temporarily  run out. This scenario was long ago discussed within ISO9001 regarding the necessary, additional, precautions required to be carried out..

Thanks for your reply - we have been trying to get COAs whenever possible and it's tough.  I like your approach and I agree with it.  Are you SQF/BRC etc. certified, and is this satisfactory to your auditing body?

We’ve been audited against SQF Fundamentals Edition 1 Manufacturing – Basic and SQF Fundamentals Edition 1 Manufacturing – Intermediate.  We are working towards an SQF Food Safety Code certification.  Fundamentals – Basic did not require a Supplier Approval Program, but Fundamentals – Intermediate did.  Our auditor did not have a problem with the way our program was written, including the part about retail raw materials, however, the Fundamentals requirements are not as rigorous as the Food Safety Code requirements.  We have over 300 raw materials, less than 2% of those are purchased from retail locations.

The SQF Approved Supplier Program Edition 9 Guidance Document states: “It [supplier approval] may be based on the risks presented by the material/input or based on historical performance or prior history of the supplier to the site.”  The very few raw materials that we purchase from retail locations are all considered low risk and the historical performance of these raw materials has been satisfactory.  Our traceability process tracks the supplier (brand) and lot number of every raw material used.  I receive e-mail updates every time there is an FDA recall, so should any of these retail items be recalled, I have a way of staying informed about it and taking appropriate action.

We’ve been audited against SQF Fundamentals Edition 1 Manufacturing – Basic and SQF Fundamentals Edition 1 Manufacturing – Intermediate.  We are working towards an SQF Food Safety Code certification.  Fundamentals – Basic did not require a Supplier Approval Program, but Fundamentals – Intermediate did.  Our auditor did not have a problem with the way our program was written, including the part about retail raw materials, however, the Fundamentals requirements are not as rigorous as the Food Safety Code requirements.  We have over 300 raw materials, less than 2% of those are purchased from retail locations.

 

The SQF Approved Supplier Program Edition 9 Guidance Document states: “It [supplier approval] may be based on the risks presented by the material/input or based on historical performance or prior history of the supplier to the site.”  The very few raw materials that we purchase from retail locations are all considered low risk and the historical performance of these raw materials has been satisfactory.  Our traceability process tracks the supplier (brand) and lot number of every raw material used.  I receive e-mail updates every time there is an FDA recall, so should any of these retail items be recalled, I have a way of staying informed about it and taking appropriate action.

Hi Spidey,

I respectfully suggest that the complete SQF Guidance regarding SAP is considerably more extensive than above quote.

The Guidance (8.1) also covers the emergency situation as mentioned in Post 4.

Interesting to hear from some GFSI/SQFusers ?.

Hi Spidey,

 

I respectfully suggest that the complete SQF Guidance regarding SAP is considerably more extensive than above quote.

 

The Guidance also covers the emergency situation as mentioned in Post 4.

 

Interesting to hear from some GFSI/SQFusers ?.

That would never fly for us, no.   We can't use anything from a retail place, no coa.  It can be challenging, due to minimums on some items being higher than we'd like, but we generally just price it in and throw out what we don't use.

It is my understanding from SQF that your risk analysis of the vendor and the ingredient determines what requires a COA. Your process parameters can also reduce risk or add to it depending on what you use the item for.  

Charles C., what are your thoughts on this avenue of thinking? Thanks!

It is my understanding from SQF that your risk analysis of the vendor and the ingredient determines what requires a COA. Your process parameters can also reduce risk or add to it depending on what you use the item for.  

 

Charles C., what are your thoughts on this avenue of thinking? Thanks!

the SQF9 Standard has -

2.3.4.2   The approved supplier program shall be based on the past performance of a supplier and the risk level of the raw materials, ingredients, processing aids, packaging, and services supplied, and shall contain at a minimum:
i.  Agreed specifications (refer to 2.3.2);
ii.  Reference to the level of risk applied to raw materials, ingredients, packaging, and services from the approved supplier;
iii.  A summary of the food safety controls implemented by the approved supplier;
iv.  Methods for granting approved supplier status;
v.  Methods and frequency of monitoring approved suppliers;
vi.  Details of the certificates of conformance, if required; and
vii.  Methods and frequency of reviewing approved supplier performance and status.

2.3.4.3   Verification of raw materials shall include certificates of conformance, certificates of analysis, or sampling, and testing. The verification frequency shall be identified by the site.

As I read the above - 

(a) SAP / 2.3.4.2 (vi) is ambiguous regarding certificate of conformance (note - not analysis), (ie when is it not required ? eg Only for Contractual reasons ?)

(b) Verification / 2.3.4.3 permits absence of COC, COA if replaced by sampling and testing.

The current SAP Guidance does not refer to COC or COA but is also IMO not compliant with the Standard's text, eg  -

[SAP] It may be based on the risks presented by the material/input or based on historical performance or prior history of the supplier to the site.

- - - - - - -

Supplier assessment should be risk-based and may be as simple as a good supply history, sourcing from certified suppliers (e.g., SQF certified suppliers)
or personally auditing/inspecting the material supplier’s operations, depending on risk, supplier knowledge and past history.

 

(Words matter :smile:)

Regardless of the above  I get the impression from previous threads that SQF auditors normally require to see COAs.. Hence my request in Post 6

PS - JFI, BRC8 has -

The company shall have a procedure for the acceptance of raw materials and primary packaging on receipt based upon the risk assessment (clause 3.5.1.1). Acceptance of raw materials (including primary packaging) and their release for use shall be based on either one or a combination of:
•  product sampling and testing
•  visual inspection on receipt
•  certificates of analysis (specific to the consignment)
•  certificates of conformance

.

Thank you, that helps a lot.  We will continue to require COAs for retail items, hard as it may be at times.  

In this context, what does SAP stand for? I'm used to the SAP computer program used for inventory/shipping/receiving/etc.  Supplier approval Process? :)

Got it. Thanks again and enjoy your day!

Thank you, that helps a lot.  We will continue to require COAs for retail items, hard as it may be at times.  

 

In this context, what does SAP stand for? I'm used to the SAP computer program used for inventory/shipping/receiving/etc.  Supplier approval Process? :)

TBH, IMO, one key requirement for an approved supplier is a mutually agreed/documented specification (SQF[i]). IMEX this auto-deletes a horde of "unknown products"