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BRC S and D - Supplier of Service vs. Subcontractor

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Zachary Agrums

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    United States

Posted 19 August 2021 - 05:50 PM

Hi all,


I'm working towards BRC S&D compliance at our site that stores and distributes shelf stable soft drinks. I'm incredibly confused about how to classify the various outside services we have as it relates to Section 3.5 - Purchasing and Section 3.5.2 - Management of Subcontractors.


From the Interpretation Guidelines:


Section 3.5 - Purchasing: "Supplier approval must include the suppliers of services that could potentially affect product safety, legality and quality; for example, the use of agencies to provide temporary staff, laundries, maintenance of equipment (e.g. refrigeration units), waste removal and transport.


Section 3.5.2 - Management of Subcontractors: "Within the context of the Standard, subcontractors are considered to be suppliers who are providing a service (related to the products) that would normally be undertaken by the audited site. The services are likely to be contracted storage, labour provision and transportation. The services may also include product-handling processes that are partially completed at another location (even at a site within the same organization or group).


The definition of subcontractor confuses me the most (service that would normally be undertaken by site). Would appreciate others' opinion on the below 3rd party services we use and whether they would be classified as a supplier of service vs. subcontractor and why:

  • Pest control
  • Facility maintenance
  • Sanitation / Janitorial
  • Transportation (Contract with transportation company A who arranges transportation with carrier companies B, C, D, etc.)

To add to the confusion, I have anecdotal evidence from colleagues at other companies who say sanitation is considered to be subcontracted while pest control is a service provider. Couldn't both of these be done by the site, thus making them both subcontracted?


Any clarity would be appreciated!





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