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Outsourced processing to a site without BRC Certification

Supplier Outsourced BRC Audit Management

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AJL

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Posted 07 January 2022 - 10:33 PM

Hi,
BRC fast approaching, and we are looking forward to it. We have not been certified before.
Basically every supplier we have ticks all the boxes, GFSI and so on.
Only one small problem here: we have a small site that we own and it produces some of the additions we add to our product at the site we want to be certified.
We are definitely not BRC ready at that site.
Does this count as an outsourced process?

How can I get around this without a multi site audit?
Has anyone been in this situation?

I have no problems whatsoever with the site, it just doesn't have enough documentation to be BRC ready.
Hope to get some guidance.
Thanks in advance.


Edited by AnnMou, 07 January 2022 - 10:34 PM.


pHruit

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Posted 08 January 2022 - 11:53 AM

From the glossary to the standard: Outsourced processing is where an intermediate production process or step in the manufacture of a product is completed at another company or site.

 

Are you sending part-finished products to your other site? It sounds more like they're supplying a finished ingredient that is then used in your product, at which point they're arguably more like a supplier than an outsourced processor.

There may be more details of which we're not aware, but my inclination would be to treat them as any other supplier, and assess/approve them accordingly - e.g. by questionnaire if justifiably low risk, or by audit. Some multi-site companies have internal programs of auditing each other as part of group internal audit processes, so if you're very lucky you might already have sufficient information accessible on file. Otherwise I'd see if you can arrange to audit them.



AJL

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Posted 08 January 2022 - 11:59 AM

Hi! Thanks so much. Yes I can see how they are more of a supplier.
They are our company, just based at a different production site.
We have a lot to do with them as they are close by, and I think the business code is the same.
So yes technically I guess they are a supplier in that they are providing us a finished product (ingredient) which is then used in our final products.

But they do not have GFSI certification which is basically a must in our supplier approval, otherwise audit like you say.
I am going to start doing a monthly internal audit, but I don't think we have time to get them on the internal audit program for a full audit across say a BRC standard.


Edited by AnnMou, 08 January 2022 - 12:03 PM.


pHruit

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Posted 08 January 2022 - 12:03 PM

It sounds like arranging a one-off "supplier" audit at the site might be a good place to start then.

Alternatively you could of course re-write your supplier approval procedure to allow approval of non-GFSI sites by questionnaire, but you'll then have to justify the low risk status and to be honest it's the sort of thing I'd expect an auditor to ask questions about, given that it's your own company ;)



AJL

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Posted 08 January 2022 - 12:13 PM

Thanks! We can't change the supplier approval process because we are just a small company part of a larger group. It's at group level that the procedures are written.


It is really giving us a bit if a headache. Our company started at the old site, but moved the majority of operations to a new site so we could meet the BRC standard.
But the old site is haunting us 🙈
To be honest I am not so concerned about the standard up there as everyone else is.

Supplier audit it is. We have actually tried to get an audit through but everyone in our quality team is so busy looking after their own sites :/
That it's hard to get stuff through.



AJL

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Posted 14 January 2022 - 08:30 PM

Hi again 🙈
I checked the definition of 'supplier' and it states:
The person, firm, company or other entity to which a site’s purchase order to supply is address.

There is no monetary exchange, with the materials arriving to our site.
So technically the smaller site is not a supplier.
I want to ensure that BRC is satisfied with the measures we have in place at the second site, but I do not want to have a multi site audit.

What's the smartest way to do this?
:)



pHruit

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Posted 15 January 2022 - 09:08 AM

How keen are you for a good old fashioned debate about semantics with your auditor? :ejut:

The glossary doesn't define what a "purchase order" is, and that's perhaps where you have flexibility - nothing in the standard states that a purchase order has to have an actual monetary value.

I appreciate that this sounds like a tenuous argument, but as someone who has worked for contract packers in the past, it's genuinely not that unusual to issue a zero-value purchase order to "buy" materials that the customer (who is also the supplier) is providing as free-issue stock.

How does your ordering/stock system handle transactions with your sister site? If you're able to do it so that you request to "buy" product from them, even if the value of that product is zero, then you have issued a purchase order and they are therefore your supplier according to BRC's definition.

 

Having said that, whilst I recognise the "fun" of going in to an audit knowing that you've got a potentially contentious area that has to be covered, it might be worth giving your certification body a call to explain the situation, just to get their confirmation that you should treat the other site as a supplier - if you can steer their thinking in that direction and get agreement from them, then you should be covered when it comes to the audit.



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Posted 15 January 2022 - 10:13 AM

Ok, thanks for the reply. My direct boss doesn't view them as a supplier. They keep saying that it is almost like they are another 'room ' in our plant. But to my mind, all of their processes are not being audited under our BRC audit, so it doesn't fly. They will need all their own paperwork and system, specific to their site. So I would be starting from scratch again.

They are technically our supplier in that way.
They do have the same business number or whatever you call it. How does that complicate things? I just want the most straight forward way to handle them and some clarity.
We are having a sort of a pre audit with our parent company, so I guess I can have their opinion.
That's in 2 weeks :/
I will look into how the transactions between sites are handled.

Any ideas ?



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Posted 16 January 2022 - 11:54 AM

Your boss's view of whether or not they are a supplier isn't necessarily going to be the same as your auditor's opinion on it ;)

But I think the only way you'll get clarity on the actual position that will be audited for BRC, is by raising the question with your certification body. Obviously this has a risk that the answer might be unhelpful to you, but it's probably better to know that in advance rather than finding out on audit day.

FWIW I've worked for multi-site companies in the past, using products from these other sites as raw materials in our processes, and never had a single auditor question the approach of treating these as suppliers.



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Posted 16 January 2022 - 03:03 PM

Thanks!!! Did you have some sites with out BRC? I will be responsible for both sites QMS, what do you think is the smartest way to manage it all? I don't think we can get to BRC standard at the smaller site.
They are actually very different processes as well.



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Posted 17 January 2022 - 07:16 PM

Thanks!!! Did you have some sites with out BRC? I will be responsible for both sites QMS, what do you think is the smartest way to manage it all? I don't think we can get to BRC standard at the smaller site.
They are actually very different processes as well.

All sites were certified to GFSI benchmarked standards, but not all BRC specifically - very much treated as "suppliers" for the purposes of our BRC audit, and I know they treated us likewise as I had to provide information to some of them for their assessment of us.

 

In terms of managing it longer-term, I'd look to harmonise as many top-level policies and procedures as you can, but obviously you'll need separate HACCP plans and, some procedures may be specific to each site. As you'll have BRC in place at one site first, I'd share that entire BRC manual with the other site as a starting point, and then only remove/add specific things to account for the differences where necessary. Even if the sites grow so much that they need their own technical manager, whoever has oversight of the overall food safety responsibility will find their job much easier if things are as standardised as possible between sites.







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