SQF 2.3.3.2 - Co-Manufacturer Requirement

Hi all,

Our site is SQF certified. We are developing our co-man approval process and policy. I do not have a lot of experience on this topic.

I am confused with 2.3.3.2 ii code, and will need some clarifications from the group. 

2.3.3.2 The site shall establish a method to determine the food safety risk level of contract manufactured product and shall document the risk. The site shall ensure that:

i. Products and processes of co-manufacturers that are considered high-risk have undergone an audit by the site or third-party agency to confirm compliance with the SQF Food Safety Code: Food Manufacturing and regulatory and customer requirements;

ii. Products and processes of co-manufacturers that are considered low-risk meet the requirements of the SQF Food Safety Code: Food Manufacturing, or other GFSI benchmarked certification programs, and regulatory and customer requirements; and

iii. Changes to contractual agreements are approved by both parties and communicated to relevant personnel.

Is it required to have a third party audit/ GFSI compliance for low risk co man? Or can we use other documents to show compliance? Some of our co man did not undergone a third party audit, and co manufacturing our product, 

Please let me know what are your thoughts, and I would appreciate if you can also provide some insight on this topic. 

Thank you!! 

I would audit those co-man's that are not third party in the very least.  Make sure your audit is based on your GFSI scheme and is robust to the risk level of what your co-man is making.  IMO that would show that your co-man is meeting the requirements of the code.  You could also request documents and go that route, but I think performing an audit would be better.  Treat it like you would for Supplier Approval.  I would also work with them to get a third party audit and look to get a GFSI audit. 

Are you promoting your GFSI certification as part of a marketing/selling point?  If so, then I would have your co-man get GFSI certified in my opinion.  

ALL of your contract manuacturers that are producing product and packaging under your label are required to either be SQF or one of the other GFSI schemes certified or at minimum meet the same requirements as your conpany sqf certification.

If they are not sqf/gfsi certified but meet all the requirements they must have an audit conducted every year.

This audit could be done by an auditing company with what is known ad a 3rd party auditor or you can undertake it as a 2nd party auditor.

If you don't have experience in auditing documentation and facility I would highly suggest a 3rd party auditor undertake the audit.