Hi Joanne,
If the material supplied is high risk then it is likely that the supplier is automatically a high-risk supplier. A medium-risk material might be assessed as high-risk where there are concerns over the supplier/country of original.
For assessment of suppliers of service, this is very dependent on the service and access to the products, for example contract cleaning in a high-risk production zone would be high risk. Cleaning of the yard by a contractor low risk. Based on the service you need to consider the risk to the safety of products, compliance with any legal requirements (such as for waste or pesticide use) and potential risks to the security of the product due to the level of access granted to the supplier. Your rating should consider the activity and then evidence of competence such as membership of trade associations, historical experience with the supplier, legal registration, certification to a relevant standard or evidence of training.
See my explanations below - BRCGS Global Standard Food Safety Issue 8 - Looking at Section 3.5 Supplier and Raw Material Approval and Performance Monitoring.
Section 3.5.1 Management of Suppliers of Raw Materials and Packaging
Clause 3.5.1.1 Interpretation from BRCGS Guidance:
When considering the risk of non-compliance with legal requirements specific to the product line (e.g. banned substances), it is important to remember that legislative requirements in the country of raw material production may be different from those of the country where the site is located. This is particularly important when importing ingredients. For example, the company should consider:
• known hazards associated with the ingredient provided or components of it (e.g. aflatoxins in nuts and cereals, histamine in fish, pesticide residues in products of plant origin, Salmonella in dried foods such as milk powder, and Listeria in chilled foods). Access to reference information and an awareness of emerging food issues are essential to ensure all known risks are assessed (clause 1.1.8)
• use of the ingredient (e.g. an ingredient added following the final kill step may present a different risk from an ingredient added at the beginning of a process)
• spread of ingredient in the company/final products
• nature of the supplier
• historical evidence of the supplier and raw material
• geographic origins (products from particular origins may carry a greater risk due to environmental conditions, because of more relaxed local legal requirements or a less developed food safety culture)
• methods of manufacture (e.g. if a site is using pineapple as an ingredient, the risk will depend on whether fresh or canned pineapple is used)
• significance of the ingredient to the final product (e.g. some ‘safe’ ingredients, such as flour in breadmaking, may be fundamental to the performance of the product and therefore require higher levels of control to ensure consistent quality)
• customer or legislative requirements (e.g. suppliers may be specified by customers, but this does not negate the need for risk assessment)
• the potential for fraudulent activity in the supply chain; for example, undeclared additions, dilution or substitution of the raw material or a component of it. (This part of the risk assessment may be completed as part of the vulnerability assessment in clause 5.4.2.)
Additional focus must be placed on raw materials where claims are being made about the final product (e.g. ‘organic’ or ‘suitable for allergy sufferers’) or where there is a microbiological risk from components added after heat treatment.
Section 3.5.3 Management of Suppliers of Services
Clause 3.5.3.1 Requirements:
There shall be a procedure for the approval and monitoring of suppliers of services. Such services shall include, as appropriate:
pest control
…..
etc.
This approval and monitoring process shall be risk-based and take into consideration:
• risk to the safety and quality of products
• compliance with any specific legal requirements
• potential risks to the security of the product (i.e. risks identified in the vulnerability and food defence assessments).
Clause 3.5.3.1 Interpretation from BRCGS Guidance:
Approval may include a combination of the following:
• membership of a recognised trade association which specialises in the service provided (e.g. pest control)
• historical experience with the supplier
• legal registration (e.g. waste licences)
• third-party certification to a recognised standard (e.g. the BRC Global Standard for Storage and Distribution)
• evidence of training and competence in food safety.
Kind regards,
Tony
