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Supplier Questionnaire for non-food contact packaging

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Patricia326

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Posted 14 January 2022 - 06:27 PM

I have a box supplier that provides a GMP audit but nothing that is GFSI compliant. Since it is non-food contact, do I still need to ask them to complete a Supplier Questionnaire?  Probably a good idea regardless, but wondering if it is required if it is non-food contact.  We are SQF certified.



jdpaul

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Posted 14 January 2022 - 06:31 PM

How is this non-food contact packaging used in the process/realization of your end product(s)?



Patricia326

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Posted 14 January 2022 - 06:35 PM

It's just the cases that hold the packaged finished product.



olenazh

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Posted 14 January 2022 - 06:35 PM

Hi Patricia; Not sure about SQF requirement, but I request all my packaging suppliers to either provide GFSI or similar OR complete a questionnaire.



jdpaul

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Posted 14 January 2022 - 06:49 PM

I see. I only ask in the case the primary packaging is susceptible to substance migration from contact with other materials. Like plastic fruit cartons that are holed. In this example, a box that holds them could very easily be consider primary packaging because it is likely to make direct contact with the product

 

However, as I see the risk on this I would not go very deep because typically just a visual inspection would indicate if there is substance contamination on the boxes


Edited by jdpaul, 14 January 2022 - 06:52 PM.


Scotty_SQF

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Posted 14 January 2022 - 07:36 PM

To me it is all in how your Supplier Approval program is written.  For example, if you have in the program that ll suppliers must complete the supplier questionnaire, then they have to complete it.  But, if you say only direct food contact suppliers must fill out the questionnaire and non-direct food contact who is risk assessed to be low risk only need to provide certain information, then you would be ok.  All up to how the program is written and what you feel is the inherent risk.



Hoosiersmoker

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Posted 19 January 2022 - 03:43 PM

Yes, have them submit a questionnaire. How else can you perform risk analysis for their materials without it? If they have a GMP program and it's non-contact, it will be reflected in the questionnaire, it will also potentially identify any gaps you might require from them or prompt a visit to inspect their facility. What if your auditor asks how you arrived at the determination they are an approved supplier? What documentation do you have and what is it based on?





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